Income Tax Issues
16th Amendment

What’s in a Name
A Brief History of the “Internal” Revenue Service

What Keeps Me up at Night Once upon an early morning dreary, while I pondered weak and weary…What’s in a name? At about 2:45 this morning, while I was writing a post on gross income (soon, my friends), the thought crossed my mind, what makes the Internal Revenue Service and the Internal Revenue Code internal? Why not simply the Revenue Service and the Revenue Code? So, I thought to myself, what’s in a name: the

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Scott St. Amand December 9, 2024
Bad Mr. Fumo

Fumo v. Commissioner
T.C. Memo. 2021-61

On May 17, 2021, the Tax Court issued a Memorandum Opinion in the case of Fumo v. Commissioner (T.C. Memo. 2021-61). The primary issue presented in Fumo v. Commissioner was whether the petitioner, who was a very bad man who defrauded community charities, was liable for excise taxes under IRC § 4958(a)(1) as a “disqualified person.” Background to Fumo v. Commissioner The petitioner, as noted above, was (and likely still is) a real jerk.  He was

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Scott St. Amand May 28, 2021
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Fumo v. Commissioner
T.C. Memo. 2021-61

On May 17, 2021, the Tax Court issued a Memorandum Opinion in the case of Fumo v. Commissioner (T.C. Memo. 2021-61). The primary issue presented in Fumo v. Commissioner was whether the petitioner, who was a very bad man who defrauded community charities, was liable for excise taxes under IRC §

Read More »
Scott St. Amand May 28, 2021