The Shortest Tax Court Opinion I’ve Seen

I’ve seen opinions of the Tax Court run to hundreds of pages on complex cases. Today, I perused what might be the shortest Tax Court decision I’ve ever seen. The petitioner erroneously filed as “Head of Household” when she should have filed as “Married, Filing Jointly (MFJ).” The IRS changed her filing status to “Single” rather than MFJ. Could she get the correct status?

Here’s the Opinion in full:

Petitioner meets the “married filing jointly” status requirements, does not meet the “head of household” or “single” filing status requirements, and thus is entitled to “married filing jointly” status. See secs. 1, 2, 6013, 7703; Ibrahim v. Commissioner, 788 F.3d 834, 840 (8th Cir. 2015) (holding that a married taxpayer who erroneously filed a “head of household” return could file jointly), rev’g and remanding T.C. Memo. 2014-8; Camara v. Commissioner, 149 T.C. ___, ___ (slip op. at 23-24) (Sept. 28, 2017) (stating that a married taxpayer may correct a “single” or “head of household” filing status claimed in error).

Contentions we have not addressed are irrelevant, moot, or meritless. [footnote omitted]

Presumably the petitioner, who was represented by counsel, had attempted to get the IRS to correct the error. One wonders why the IRS wouldn’t make the change to what is the correct filing status; thus, this case ended up at Tax Court. Then again, given some of the things I’ve seen perhaps I don’t need to wonder….

Case: Godsey v. Commissioner, T.C. Memo 2017-214

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