Income Tax Issues
Income Tax Issues / Memorandum Opinions / Tax Opinions

Ryder & Associates Inc. v. Commissioner
T.C. Memo. 2021-88

On July 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Ryder & Associates Inc. v. Commissioner (T.C. Memo. 2021-88). The primary issues presented in Ryder & Associates Inc. v. Commissioner were whether the petitioners received unreported gross receipts from their company, and whether the petitioners had significant unreported dividend income. Author’s Note on Ryder & Associates v. Commissioner As I mentioned earlier this year, I have never seen it bode well for a petitioner to whom the Tax Court describes first in the background of the case as a tax attorney.  Not only was Mr. Ryder a tax attorney, but he also held his LLM in taxation from NYU. Not only was Mr. Ryder a tax attorney, but he specialized in ERISA and qualified retirement plans. Not only did he specialize in ERISA and qualified retirement plans, but the IRS also determined that he had bamboozled the…

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July 29, 2021
Income Tax Issues
Income Tax Issues / Memorandum Opinions / Tax Opinions

Blossom Day Care Centers Inc. v. Commissioner
T.C. Memo. 2021-87

On July 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Blossom Day Care Centers Inc. v. Commissioner (T.C. Memo. 2021-87). The primary issues presented in Blossom Day Care Centers Inc. v. Commissioner were whether the petitioner was failed to report capital gain and gross receipts, whether the petitioner is entitled to certain deductions, whether the petitioner is entitled to Indian tax credits, and most importantly, whether the petitioner is liable for the civil fraud penalty under IRC § 6663. Background to Blossom Day Care Centers Inc. v. Commissioner July 13, 2021, had not started out as what you would call a “good” Tuesday for the Hackers or their Oklahoma daycare conglomerate, as evidenced by their total loss in the employment tax case discussed in a previous post. For more detailed background, you can refer to Briefly Taxing’s summary of Blossom Day Care Centers, Inc. v. Commissioner,…

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July 29, 2021