Distributions

Ward v. Commissioner (T.C. Memo. 2021-32)

On March 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Ward v. Commissioner (T.C. Memo. 2021-32). The primary issues presented in Ward were whether the petitioner properly reported income, whether the petitioner was entitled to the insolvency exception to IRC § 108 to avoid income inclusion for discharge of indebtedness income, and whether the petitioner was just completely full of shit. She was. Personal Note I sympathize with the petitioner

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Corporations

De Los Santos v. Commissioner (156 T.C. No. 9)

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or shareholders, and, in turn, whether such economic benefits or taxable to the petitioner’s as ordinary compensation income or as a distribution under IRC § 301. The

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Ward v. Commissioner (T.C. Memo. 2021-32)

On March 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Ward v. Commissioner (T.C. Memo. 2021-32). The primary issues presented in Ward were whether the petitioner properly reported income, whether the petitioner was entitled to the insolvency exception to IRC § 108 to avoid income

Read More »

De Los Santos v. Commissioner (156 T.C. No. 9)

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or shareholders,

Read More »