Accuracy Related Penalty

Vennes v. Commissioner (T.C. Memo. 2021-93)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty pursuant to IRC § 6662(a). A Checkered Past In 1990, the petitioner completed a prison sentence for money laundering, narcotics, and firearms offenses. After his

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Deductions

Geiman v. Commissioner (T.C. Memo. 2021-80)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background The petitioner is a union electrician who spent most of 2013 on jobs in various parts of Wyoming and Colorado. He claimed on his 2013 Federal

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Deductions

Nurumbi v. Commissioner (T.C. Memo. 2021-79)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for vehicles for hire applied. Held:  Background The petitioner was an Uber pimp. He maintained a stable of Uber drivers under his iron fist and gold

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Deductions

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to IRC § 165. Background As of 2016, the petitioner was illiterate—whether because of an illness or because he didn’t ascribe much to them book learnings,

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Capitalization

Mylan Inc. v. Commissioner (156 T.C. No. 10)

On April 27, 2021, the Tax Court issued its opinion in Mylan, Inc. v. Commissioner, 156 T.C. No. 10. The underlying issues presented in Mylan, Inc. were (1) whether the legal expenses incurred in preparing notice letters to brand name drug companies of petitioner’s intent to make generic versions of its drugs as part of the FDA approval process to do the same were capital or ordinary expenses; and (2) whether the legal expenses incurred

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Charitable Contributions

Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62)

On May 17, 2021, the Tax Court issued a Memorandum Opinion in the case of Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62). The primary issue presented in Montgomery-Alabama River was whether the Tax Court should certify (to the Alabama Supreme Court) the question of whether, under Alabama law, the petitioner would be entitled to the full proceeds of any sale if the easement were extinguished. Basic Legal Framework The governing regulation requires that the

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Accuracy Related Penalty

Berry v. Commissioner (T.C. Memo. 2021-52)

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is entitled to deduct racecar expenses, and whether or not the petitioners substantiated COGS or a depreciation deduction under IRC § 167(a). Background You may remember

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Vennes v. Commissioner (T.C. Memo. 2021-93)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty

Read More »

Geiman v. Commissioner (T.C. Memo. 2021-80)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background The

Read More »

Nurumbi v. Commissioner (T.C. Memo. 2021-79)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for

Read More »

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to

Read More »

Mylan Inc. v. Commissioner (156 T.C. No. 10)

On April 27, 2021, the Tax Court issued its opinion in Mylan, Inc. v. Commissioner, 156 T.C. No. 10. The underlying issues presented in Mylan, Inc. were (1) whether the legal expenses incurred in preparing notice letters to brand name drug companies of petitioner’s intent to make generic versions of

Read More »

Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62)

On May 17, 2021, the Tax Court issued a Memorandum Opinion in the case of Montgomery-Alabama River, LLC v. Commissioner (T.C. Memo. 2021-62). The primary issue presented in Montgomery-Alabama River was whether the Tax Court should certify (to the Alabama Supreme Court) the question of whether, under Alabama law, the

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Berry v. Commissioner (T.C. Memo. 2021-52)

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is

Read More »