Income Tax Issues
Books and Records

Safaryan v. Commissioner
T.C. Memo. 2021-138

On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held: Not so much. Background to Safaryan v. Commissioner In 2012 or 2013 the petitioner-husband purchased 10 acres of property in Newberry Springs, California. The property

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Scott St. Amand April 24, 2022
Penalties Under the Code
Accuracy Related Penalty

Soni v. Commissioner
T.C. Memo. 2021-137

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Soni v. Commissioner (T.C. Memo. 2021-137). The primary issues presented in Soni were (1) whether the petitioners filed a valid joint return; (2) whether the period of limitations for assessment of tax under IRC § 6501(a) and (c)(4) expired before the issuance of the notice of deficiency; (3) whether the petitioners are liable for an addition to tax under IRC

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Scott St. Amand April 23, 2022
Procedural Issues
31 C.F.R. § 10.0

FAB Holdings LLC v. Commissioner
T.C. Memo. 2021-135

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of FAB Holdings LLC v. Commissioner (T.C. Memo. 2021-135). The primary issue presented in FAB Holdings was whether the statutory notices of deficiency (SNODs) were timely sent based upon a cockamamy argument that the petitioners’ CPA was a “promoter” because the petitioners paid for his services. Held: The Tax Court was “not persuaded” by such argument. Background to FAB Holdings LLC

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Scott St. Amand April 21, 2022
Procedural Issues
Burden of Proof

Spain v. Commissioner
T.C. Memo. 2021-58

On May 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Spain v. Commissioner (T.C. Memo. 2021-58). The primary issue presented in Spain v. Commissioner was whether the petitioners proved that their petition had been timely mailed such that the Tax Court had jurisdiction to entertain their case. The Timing Issue in Spain v. Commissioner The IRS issued petitioners separate notices of determination dated September 10, 2019, sustaining the underlying collection action.

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Scott St. Amand May 11, 2021
Penalties Under the Code
Burden of Proof

Jenkins v. Commissioner
T.C. Memo. 2021-54

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Jenkins v. Commissioner (T.C. Memo. 2021-54). The primary issues presented in Jenkins v. Commissioner was whether the IRS has proven fraud, and the amount of unreported income for the consolidated petitioners. Just a Head’s Up re: Jenkins v. Commissioner This opinion by Judge Holmes contains a “waddle” of penguins that speak in French, a forged Kerguelenois diplomatic passport, and a

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Scott St. Amand May 10, 2021
Procedural Issues
Burden of Proof

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule 231. A Lawyer, Scholar, and Author in Jacobs v. Commissioner The petitioner was a trial lawyer with the Department of Justice for 20 years before

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Scott St. Amand May 5, 2021
Income Tax Issues
Books and Records

Chancellor v. Commissioner
T.C. Memo. 2021-50

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor v. Commissioner was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local tax. Brief Background to Chancellor v. Commissioner Ms. Viola Chancellor, of Nevada, is a notary and a paralegal.  In 2015, she received $400 from her

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Scott St. Amand May 4, 2021
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Safaryan v. Commissioner
T.C. Memo. 2021-138

On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held:

Read More »
Scott St. Amand April 24, 2022

Soni v. Commissioner
T.C. Memo. 2021-137

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Soni v. Commissioner (T.C. Memo. 2021-137). The primary issues presented in Soni were (1) whether the petitioners filed a valid joint return; (2) whether the period of limitations for assessment of tax under IRC §

Read More »
Scott St. Amand April 23, 2022

FAB Holdings LLC v. Commissioner
T.C. Memo. 2021-135

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of FAB Holdings LLC v. Commissioner (T.C. Memo. 2021-135). The primary issue presented in FAB Holdings was whether the statutory notices of deficiency (SNODs) were timely sent based upon a cockamamy argument that the petitioners’ CPA

Read More »
Scott St. Amand April 21, 2022

Spain v. Commissioner
T.C. Memo. 2021-58

On May 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Spain v. Commissioner (T.C. Memo. 2021-58). The primary issue presented in Spain v. Commissioner was whether the petitioners proved that their petition had been timely mailed such that the Tax Court had jurisdiction to entertain their

Read More »
Scott St. Amand May 11, 2021

Jenkins v. Commissioner
T.C. Memo. 2021-54

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Jenkins v. Commissioner (T.C. Memo. 2021-54). The primary issues presented in Jenkins v. Commissioner was whether the IRS has proven fraud, and the amount of unreported income for the consolidated petitioners. Just a Head’s Up

Read More »
Scott St. Amand May 10, 2021

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule

Read More »
Scott St. Amand May 5, 2021

Chancellor v. Commissioner
T.C. Memo. 2021-50

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor v. Commissioner was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local

Read More »
Scott St. Amand May 4, 2021