Income Tax Issues
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 v. Commissioner 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. The Basic Nature of Deductions in Williams v.

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Scott St. Amand April 14, 2020
Income Tax Issues
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 v. Commissioner 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. Background to Pinkston v. Commissioner In 2003 and 2010, the petitioners acquired two rental

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Scott St. Amand April 13, 2020
Income Tax Issues
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 v. Commissioner 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

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Scott St. Amand April 9, 2020
Income Tax Issues
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 v. Commissioner 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

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Scott St. Amand April 6, 2020
Income Tax Issues
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 v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses in General as explained by Christensen v. Commissioner Because deductions are a “matter of legislative grace,” taxpayers bear the burden of establishing their entitlement thereto.

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Scott St. Amand January 15, 2020
Income Tax Issues
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 Cuthbertson v. Commissioner 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

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Scott St. Amand January 14, 2020
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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 v. Commissioner was whether the petitioners were entitled to deductions on Schedule C (Profit or Loss from Business) for the expenses

Read More »
Scott St. Amand April 14, 2020

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 v. Commissioner was whether the IRS appropriately “recaptured” depreciation deductions that the petitioners claimed on rental properties prior to the years

Read More »
Scott St. Amand April 13, 2020

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 v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue;

Read More »
Scott St. Amand April 9, 2020

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 v. Commissioner was whether the petitioner’s payments to his former spouse, which, under the terms of a divorce decree, ended at his

Read More »
Scott St. Amand April 6, 2020

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 v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses

Read More »
Scott St. Amand January 15, 2020

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 Cuthbertson v. Commissioner were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2)

Read More »
Scott St. Amand January 14, 2020