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 v. Commissioner are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.
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. v. Commissioner. 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
On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions were adjusted in the IRS’s amended answer. Background to Simpson v. Commissioner The IRS issued the petitioners a notice of deficiency for tax years 2012,
On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Johnson v. Commissioner (T.C. Memo. 2020-79). The issues before the court in Johnson v. Commissioner were (1) whether the petitioner is entitled to deduct certain expenses on his Schedules F (Profit or Loss from Farming) for the years in issue; and (2) the valuation of a conservation easement. Driving Between Two Places of Business Deductible (if One is Not Your
On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Brannan Sand & Gravel Co. LLC v. Commissioner (T.C. Memo. 2020-76). The issue before the court in Brannan Sand & Gravel Co. LLC v. Commissioner was whether the petitioner substantiated (as required by Treas. Reg. § 1.170A-13(c)) a $200,000 charitable contribution claimed for the donation of certain water storage rights. Background to Donation in Brannan Sand & Gravel Co. LLC v.
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 v. Commissioner 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
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 v. Commissioner 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
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 v. Commissioner are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.
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. v. Commissioner. were whether the accrued production costs were: (1) fixed and binding where
On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions
On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Johnson v. Commissioner (T.C. Memo. 2020-79). The issues before the court in Johnson v. Commissioner were (1) whether the petitioner is entitled to deduct certain expenses on his Schedules F (Profit or Loss from Farming)
On June 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Brannan Sand & Gravel Co. LLC v. Commissioner (T.C. Memo. 2020-76). The issue before the court in Brannan Sand & Gravel Co. LLC v. Commissioner was whether the petitioner substantiated (as required by Treas. Reg. §
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 v. Commissioner were (1) whether the petitioner is entitled to additional costs of goods sold or deductions for business
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 v. Commissioner were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2)
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