Income Tax Issues
Bank Deposits Analysis

Haghnazarzadeh v. Commissioner
T.C. Memo. 2021-47

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh v. Commissioner was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context to Haghnazarzadeh v. Commissioner This is an unreported income case, and the opinion is all of six pages long.  One has expectations of a couple thousand

Read More »
Scott St. Amand April 29, 2021
Income Tax Issues
Bank Deposits Analysis

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for filing (very) late and for being (very) negligent and for (very) substantially understating their liabilities. Background to NOLs in Martin v. Commissioner The

Read More »
Scott St. Amand March 14, 2021
Business Related Issues
Badges of Fraud

Collins v. Commissioner
T.C. Memo. 2020-50

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins v. Commissioner were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the petitioners are liable for additions to tax for failing to timely file their returns; and whether petitioner-husband is liable for the civil fraud

Read More »
Scott St. Amand April 23, 2020
Penalties Under the Code
A Petitioner Named Dung

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for 2006; (2) whether the petitioners failed to report gross receipts on Schedule C (Profits or Loss From Business) with regard to their nail salons in

Read More »
Scott St. Amand February 26, 2020
Income Tax Issues
Al Capone

Onyeani v. Commissioner
T.C. Memo. 2020-15

On January 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Onyeani v. Commissioner (T.C. Memo. 2020-15). The issue presented in Onyeani v. Commissioner was whether the IRS appropriately issued a termination assessment against the petitioner and determined that his illegal income was taxable. Note on Onyeani v. Commissioner Hello, dear reader, I am Ogorji Timothy Wilson Onyeani, a Nigerian doctor, who has come upon a sum of money in the

Read More »
Scott St. Amand January 16, 2020
Income Tax Issues
Accuracy Related Penalty

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

Read More »
Scott St. Amand January 13, 2020
Business Related Issues
Abuse of Discretion

Hommel v. Commissioner
T.C. Memo. 2020-4

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel v. Commissioner was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue, however, was how close Judge Holmes could get to calling the petitioner a #^&%$ idiot without actually doing so. Personal Note in Hommel

Read More »
Scott St. Amand January 8, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Haghnazarzadeh v. Commissioner
T.C. Memo. 2021-47

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh v. Commissioner was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context to

Read More »
Scott St. Amand April 29, 2021

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for

Read More »
Scott St. Amand March 14, 2021

Collins v. Commissioner
T.C. Memo. 2020-50

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins v. Commissioner were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2)

Read More »
Scott St. Amand April 23, 2020

Tran v. Commissioner
T.C. Memo. 2020-27

On February 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Tran v. Commissioner (T.C. Memo. 2020-27). The three primary issues presented in Tran v. Commissioner were (1) whether the IRS is barred by the doctrine of collateral estoppel from relitigating the petitioners’ tax liability for

Read More »
Scott St. Amand February 26, 2020

Onyeani v. Commissioner
T.C. Memo. 2020-15

On January 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Onyeani v. Commissioner (T.C. Memo. 2020-15). The issue presented in Onyeani v. Commissioner was whether the IRS appropriately issued a termination assessment against the petitioner and determined that his illegal income was taxable. Note on

Read More »
Scott St. Amand January 16, 2020

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to

Read More »
Scott St. Amand January 13, 2020

Hommel v. Commissioner
T.C. Memo. 2020-4

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel v. Commissioner was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The

Read More »
Scott St. Amand January 8, 2020