Procedural Issues
Bankruptcy

Wathen v. Commissioner (T.C. Memo. 2021-100)

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable for the failure to file penalty for 2010 and 2011, and whether the petitioner is liable for the substantial understatement accuracy-related penalty. Background to Wathen

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Taxing, Briefly
Bankruptcy

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He took the owl everywhere, which naturally led to many a calamity when Stuffy was inevitably misplaced. For my wife and I, Stuffy also had an

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Procedural Issues
Abuse of Discretion

Barnes v. Commissioner (T.C. Memo. 2021-49)

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Barnes v. Commissioner (T.C. Memo. 2021-49). The primary issues presented in Barnes were whether the statute of limitations on collections had run with respect to the petitioners 2003 liability, whether their 2003 tax liability had been discharged in bankruptcy, whether the IRS abused its discretion in sustaining a Notice of Federal Tax Lien as to the 2003 liability. Background The

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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 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 The petitioner-husband was a racecar driver and

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Wathen v. Commissioner (T.C. Memo. 2021-100)

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable

Read More »

Taxing, Briefly – Can the IRS Take My Passport?

When my son was two, his grandmother gave him a stuffed owl. Not a particularly creative toddler, he named the little owl Stuffy, and the name has stuck to this day.  What does this have to do with the question “Can the IRS Take My Passport?”  Patience…all will be revealed. He

Read More »

Barnes v. Commissioner (T.C. Memo. 2021-49)

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Barnes v. Commissioner (T.C. Memo. 2021-49). The primary issues presented in Barnes were whether the statute of limitations on collections had run with respect to the petitioners 2003 liability, whether their 2003 tax liability had

Read More »

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 were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for

Read More »