Badges of Fraud

Collins v. Commissioner (T.C. Memo. 2020-50)

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the petitioners are liable for additions to tax for failing to timely file their returns; and whether petitioner-husband is liable for the civil fraud penalty of

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Books and Records

Williams v. Commissioner (T.C. Memo. 2020-48)

On April 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Williams v. Commissioner (T.C. Memo. 2020-48). The primary issue before the court in Williams was whether the petitioners were entitled to deductions on Schedule C (Profit or Loss from Business) for the expenses of the petitioner-husband’s new business venture as he grew it and prior to the business’ actual operation.

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Deductions

Pinkston v. Commissioner (T.C. Memo. 2020-44)

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Pinkston v. Commissioner (T.C. Memo. 2020-44). The issue properly before the court in Pinkston was whether the IRS appropriately “recaptured” depreciation deductions that the petitioners claimed on rental properties prior to the years at issue, as to which years the limitation period had expired.

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Accuracy Related Penalty

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for the IRC

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Alimony

Biddle v. Commissioner (T.C. Memo. 2020-39)

On April 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Biddle v. Commissioner (T.C. Memo. 2020-39). The issue before the court in Biddle was whether the petitioner’s payments to his former spouse, which, under the terms of a divorce decree, ended at his youngest child’s 18th birthday, were deductible alimony payments under IRC § 215 or whether the contingency related to his children transformed the “alimony” into nondeductible child support.

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Deductibility of Expenses

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a).

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Bad Advice

Cuthbertson v. Commissioner (T.C. Memo. 2020-9)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Cuthbertson v. Commissioner (T.C. Memo. 2020-9). The issues presented in Culbertson were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2) whether the installment method of accounting was an appropriate method of accounting to report the transfer of property between two companies, both wholly owned by the petitioners.

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Collins v. Commissioner (T.C. Memo. 2020-50)

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the

Read More »

Williams v. Commissioner (T.C. Memo. 2020-48)

On April 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Williams v. Commissioner (T.C. Memo. 2020-48). The primary issue before the court in Williams was whether the petitioners were entitled to deductions on Schedule C (Profit or Loss from Business) for the expenses of the

Read More »

Pinkston v. Commissioner (T.C. Memo. 2020-44)

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Pinkston v. Commissioner (T.C. Memo. 2020-44). The issue properly before the court in Pinkston was whether the IRS appropriately “recaptured” depreciation deductions that the petitioners claimed on rental properties prior to the years at issue,

Read More »

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether

Read More »

Biddle v. Commissioner (T.C. Memo. 2020-39)

On April 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Biddle v. Commissioner (T.C. Memo. 2020-39). The issue before the court in Biddle was whether the petitioner’s payments to his former spouse, which, under the terms of a divorce decree, ended at his youngest child’s

Read More »

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a).

Read More »

Cuthbertson v. Commissioner (T.C. Memo. 2020-9)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Cuthbertson v. Commissioner (T.C. Memo. 2020-9). The issues presented in Culbertson were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2) whether the

Read More »