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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Business Related Issues
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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Business Related Issues
Change in Accounting Method

Richmond Patients Group v. Commissioner (T.C. Memo. 2020-52)

On May 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Richmond Patients Group v. Commissioner (T.C. Memo. 2020-52). The issues before the court in Richmond Patients Group were (1) whether the petitioner is entitled to additional costs of goods sold or deductions for business expenses; (2) whether the petitioner was a reseller or a producer of marijuana pursuant to IRC § 471 during the years in issue; (3) whether the

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Business Related Issues
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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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 »

Richmond Patients Group v. Commissioner (T.C. Memo. 2020-52)

On May 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Richmond Patients Group v. Commissioner (T.C. Memo. 2020-52). The issues before the court in Richmond Patients Group were (1) whether the petitioner is entitled to additional costs of goods sold or deductions for business expenses;

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 »