Procedural Issues
Bad Debt Deductions

Kelly v. Commissioner
T.C. Memo. 2021-76

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly v. Commissioner were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or cancellation of indebtedness (COD) income when the loans were cancelled. Background to Kelly v. Commissioner The petitioner was a 50% owner of Lucky Bastard Records.

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Scott St. Amand July 12, 2021
Business Related Issues
Basis in Partnership

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as contributions upon dissolution, resulted in cancellation of indebtedness income. Background to Hohl et al. v. Commissioner Hohl, Blake, and Bowles were partners in a partnership

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Scott St. Amand January 13, 2021
Income Tax Issues
Cancellation of Indebtedness (COD) Income

Wienke v. Commissioner
T.C. Memo. 2020-143

On October 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Wienke v. Commissioner (T.C. Memo. 2020-143). The issues before the court in Wienke v. Commissioner are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.

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Scott St. Amand October 14, 2020
Penalties Under the Code
Burden of Proof

Duffy v. Commissioner
T.C. Memo. 2020-108

On July 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Duffy v. Commissioner (T.C. Memo. 2020-108). The primary issue before the court in Duffy v. Commissioner was whether, because the petitioners’ debt to the bank was nonrecourse, the discharge of indebtedness was included in the petitioners amount realized on the sale of the property and did not give rise to cancellation of indebtedness income under Treas. Reg. § 1.1001-2(a). A

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Scott St. Amand July 13, 2020
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Kelly v. Commissioner
T.C. Memo. 2021-76

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly v. Commissioner were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or

Read More »
Scott St. Amand July 12, 2021

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as

Read More »
Scott St. Amand January 13, 2021

Wienke v. Commissioner
T.C. Memo. 2020-143

On October 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Wienke v. Commissioner (T.C. Memo. 2020-143). The issues before the court in Wienke v. Commissioner are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.

Read More »
Scott St. Amand October 14, 2020

Duffy v. Commissioner
T.C. Memo. 2020-108

On July 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Duffy v. Commissioner (T.C. Memo. 2020-108). The primary issue before the court in Duffy v. Commissioner was whether, because the petitioners’ debt to the bank was nonrecourse, the discharge of indebtedness was included in the

Read More »
Scott St. Amand July 13, 2020