Income Tax Issues
Child Support

Hicks v. Commissioner
T.C. Memo. 2022-10

On February 23, 2022, the Tax Court issued a Memorandum Opinion in the case of Hicks v. Commissioner (T.C. Memo. 2022-10). The primary issue presented in Hicks v. Commissioner was whether the petitioner was entitled to the dependency exemption deductions and child tax credits claimed on his income tax return. Background to Hicks v. Commissioner The petitioner has two children with one Ms. Oddimissia N. Johnson who were minors in 2014, the year at issue.

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Scott St. Amand May 17, 2022
Income Tax Issues
Accuracy Related Penalty

Leyh v. Commissioner
157 T.C. No. 7

On October 4, 2021, the Tax Court issued its opinion in Leyh v. Commissioner (157 T.C. No. 7). The primary issue presented in Leyh v. Commissioner was whether the petitioner was entitled to deduct, as alimony, an amount equal to the premiums paid to provide health insurance coverage for his then spouse Held:  Yes, sir. Background to Leyh v. Commissioner In 2012, the petitioner in Leyh v. Commissioner, Mr. Leyh, filed for divorce from his then wife,

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Scott St. Amand October 10, 2021
Income Tax Issues
Contingent Fees

Holliday v. Commissioner
T.C. Memo. 2021-69

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday v. Commissioner was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background to Holliday v. Commissioner Two lawsuits are central to this case. The first is petitioner’s divorce proceeding, in which she was represented by J. Beverly and his law firm (divorce attorney and malpractice defendants,

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Scott St. Amand June 21, 2021
Income Tax Issues
Divorce

Grossman v. Commissioner
T.C. Memo. 2021-65

On May 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Grossman v. Commissioner (T.C. Memo. 2021-65). The primary issue presented in Grossman v. Commissioner was whether state law determines a taxpayer’s marital status at death for purposes of the marital deduction under IRC § 2056(a). The Saga of Semone in Grossman v. Commissioner All Semone Grossman wanted was to find a nice Jewish girl to settle down with. He had survived

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Scott St. Amand June 21, 2021
Income Tax Issues
Actual Knowledge

A Deep Dive into Innocent Spouse Relief

Uncle Bill has four children…that he knows of. We met Jedediah in a previous post. Jethro is on year four of his five-year stint at Raiford for possession of amphetamines with intent to distribute. In his defense, Jethro agreed with the officer that the crank was his.  However, he vehemently denied that he had any intent whatsoever to share it with anyone else. (Candidly, you absolutely believe him.)  Bill and Ethel’s daughters Jennie and Jaime

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Scott St. Amand April 29, 2021
Income Tax Issues
Ailurophobia

Ex-Spousal Transfers of Property Long After Divorce

On February 14, 2013, Jethro and Lee Ann’s divorce became final.  Though the divorce was a foregone conclusion in your view, given Jethro’s unrepentant kleptomania and penchant for setting things on fire, still Uncle Bill and Aunt Ethel are torn up about their only son’s marital woes.  You think your lucky stars that you are a tax attorney and stay away from family law like the plague. Nonetheless, you have developed relationships with the family

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Scott St. Amand April 29, 2021
Income Tax Issues
Divorce

Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax items attributable to her ex-husband for the years at issue, even though her ex-husband (the intervenor) opposed the relief.

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Scott St. Amand November 4, 2020
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Hicks v. Commissioner
T.C. Memo. 2022-10

On February 23, 2022, the Tax Court issued a Memorandum Opinion in the case of Hicks v. Commissioner (T.C. Memo. 2022-10). The primary issue presented in Hicks v. Commissioner was whether the petitioner was entitled to the dependency exemption deductions and child tax credits claimed on his income tax return.

Read More »
Scott St. Amand May 17, 2022

Leyh v. Commissioner
157 T.C. No. 7

On October 4, 2021, the Tax Court issued its opinion in Leyh v. Commissioner (157 T.C. No. 7). The primary issue presented in Leyh v. Commissioner was whether the petitioner was entitled to deduct, as alimony, an amount equal to the premiums paid to provide health insurance coverage for his then

Read More »
Scott St. Amand October 10, 2021

Holliday v. Commissioner
T.C. Memo. 2021-69

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday v. Commissioner was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background to Holliday v. Commissioner Two lawsuits are central to

Read More »
Scott St. Amand June 21, 2021

Grossman v. Commissioner
T.C. Memo. 2021-65

On May 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Grossman v. Commissioner (T.C. Memo. 2021-65). The primary issue presented in Grossman v. Commissioner was whether state law determines a taxpayer’s marital status at death for purposes of the marital deduction under IRC § 2056(a).

Read More »
Scott St. Amand June 21, 2021

A Deep Dive into Innocent Spouse Relief

Uncle Bill has four children…that he knows of. We met Jedediah in a previous post. Jethro is on year four of his five-year stint at Raiford for possession of amphetamines with intent to distribute. In his defense, Jethro agreed with the officer that the crank was his.  However, he vehemently

Read More »
Scott St. Amand April 29, 2021

Ex-Spousal Transfers of Property Long After Divorce

On February 14, 2013, Jethro and Lee Ann’s divorce became final.  Though the divorce was a foregone conclusion in your view, given Jethro’s unrepentant kleptomania and penchant for setting things on fire, still Uncle Bill and Aunt Ethel are torn up about their only son’s marital woes.  You think your

Read More »
Scott St. Amand April 29, 2021

Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax

Read More »
Scott St. Amand November 4, 2020