Income Tax Issues
COGS

Today’s Health Care II LLC v. Commissioner (T.C. Memo. 2021-96)

On August 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Today’s Health Care II LLC v. Commissioner (T.C. Memo. 2021-96). The primary issue presented in Today’s Health Care was whether IRC § 280E (Expenditures in Connection with the Illegal Sale of Drugs) violated the Eighth or Sixteenth Amendments to the Constitution. Held: Not today, hippie. Note: Even the initials of the company (T.H.C.) are pot-induced. Kudos, stoners. Background to Today’s

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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 are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.

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COGS

Morning Star Packing Company L.P. v. Commissioner (T.C. Memo. 2020-142)

On October 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Morning Star Packing Company, L.P. v. Commissioner (T.C. Memo. 2020-141). The issues before the court in Morning Star Packing Company, L.P. were whether the accrued production costs were: (1) fixed and binding where economic performance did not occur until the year following the tax year claimed for and (2) whether the partnerships’ inclusion of such production costs in COGS for

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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 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.

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Today’s Health Care II LLC v. Commissioner (T.C. Memo. 2021-96)

On August 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Today’s Health Care II LLC v. Commissioner (T.C. Memo. 2021-96). The primary issue presented in Today’s Health Care was whether IRC § 280E (Expenditures in Connection with the Illegal Sale of Drugs) violated the Eighth

Read More »

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 are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.

Read More »

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 was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue,

Read More »