On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Novoselsky v. Commissioner (T.C. Memo. 2020-68). The issues before the court in Novoselsky v. Commissioner were (1) whether (1) the litigation advance support payments were loans or gross income, and whether petitioners were liable for accuracy-related penalties. Background Facts to Novoselsky v. Commissioner During 2009 and 2011, the petitioner-husband (PH) practiced law with a focus on class action litigation. In