Penalties Under the Code
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Chiarelli v. Commissioner
T.C. Memo. 2021-27

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Chiarelli v. Commissioner (T.C. Memo. 2021-27). The primary issues presented in Chiarelli v. Commissioner were whether the petitioner was entitled to noncash charitable contribution deductions for the years at issue and whether the petitioner was liable for the IRC § 6662(a) accuracy-related penalties for 2012 and 2013. Incomplete Form 8283 in Chiarelli v. Commissioner The petitioner inherited valuable property from his late mother, had the items appraised by an auction company, and donated significant portions of the property, claiming charitable deductions of $90,000 in 2012, $93,000 in 2012, and $77,000 in 2015, respectively.  For each of the years at issue Section A of Form 8283 directed petitioner to list each item or group of similar items of donated property with a value of $5,000 or less and provide the name and address of the donee…

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March 3, 2021
Read more about the article Pankratz v. Commissioner <section> T.C. Memo. 2021-26 </section>
Tax Opinions / Charitable Issues / Memorandum Opinions

Pankratz v. Commissioner
T.C. Memo. 2021-26

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz v. Commissioner was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his tax returns before filing. Introductory Notes: I cannot say for sure whether the return preparers were actually the fire chief and the village idiot, but they might be.  The only thing that cuts against this supposition is that if Judge Holmes had caught wind of such a happening, you can be damn sure that he would have mentioned it in a footnote.  Or seven. Background to Pankratz v. Commissioner The petitioner was a successful veterinarian, who (on a dare, it seems) invented a vaccine for a particular animal virus that caught the attention of the USDA.  Though the…

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March 3, 2021