Income Tax Issues
Accuracy Related Penalty

Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay advance premium tax credit (APTC) payments of the PTC. Held: Yup and yeppers. Background to Knox v. Commissioner The petitioners were (and perhaps still are)

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Scott St. Amand March 30, 2022
Income Tax Issues
Advanced Premium Tax Credit

Amburgey v. Commissioner
T.C. Memo. 2021-124

On November 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Amburgey v. Commissioner (T.C. Memo. 2021-124). The primary issue presented in Amburgey v. Commissioner was whether the petitioners were required to repay an advance premium tax credit, or whether requiring them to do so was unconstitutional. Held: Pay up, petitioners. Background to Amburgey v. Commissioner The petitioners, a married couple, reported an adjusted gross income of $181,183 on their joint

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Scott St. Amand November 15, 2021
Income Tax Issues
Acronym Soup

Abrego v. Commissioner
T.C. Memo. 2020-87

On June 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Abrego v. Commissioner (T.C. Memo. 2020-87). The issue before the court in Abrego v. Commissioner was whether the petitioners received excess advance payments of the premium assistance tax credit (commonly known as the premium tax credit or PTC) allowed under section 1412 of the Patient Protection and Affordable Care Act, which in turn increased their tax due by the amount

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Scott St. Amand June 16, 2020
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Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay

Read More »
Scott St. Amand March 30, 2022

Amburgey v. Commissioner
T.C. Memo. 2021-124

On November 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Amburgey v. Commissioner (T.C. Memo. 2021-124). The primary issue presented in Amburgey v. Commissioner was whether the petitioners were required to repay an advance premium tax credit, or whether requiring them to do so was

Read More »
Scott St. Amand November 15, 2021

Abrego v. Commissioner
T.C. Memo. 2020-87

On June 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Abrego v. Commissioner (T.C. Memo. 2020-87). The issue before the court in Abrego v. Commissioner was whether the petitioners received excess advance payments of the premium assistance tax credit (commonly known as the premium tax

Read More »
Scott St. Amand June 16, 2020