Income Tax Issues
CDP

Parker v. Commissioner (T.C. Memo. 2021-111)

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Parker v. Commissioner (T.C. Memo. 2021-111). The primary issues presented in Parker were (1) whether petitioners can deduct, on Schedule C (Profit or Loss From Business), car and truck expenses in excess of the amount the IRS allowed; (2) whether petitioners can deduct retirement contributions in excess of the amount the IRS allowed; (3) whether petitioners can deduct expenses on

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Income Tax Issues
Deductions

Nurumbi v. Commissioner (T.C. Memo. 2021-79)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for vehicles for hire applied. Held:  Background The petitioner was an Uber pimp. He maintained a stable of Uber drivers under his iron fist and gold

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Bad Debt Losses

Franklin v. Commissioner (T.C. Memo. 2020-127)

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled to deduct certain business losses.

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Badges of Fraud

Collins v. Commissioner (T.C. Memo. 2020-50)

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 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 penalty of

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

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Income Tax Issues
Books and Records

Near v. Commissioner (T.C. Memo. 2020-10)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when the employee had a right to seek reimbursement from his employer.

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Income Tax Issues
Accuracy Related Penalty

Rivera v. Commissioner (T.C. Memo. 2020-7)

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

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Parker v. Commissioner (T.C. Memo. 2021-111)

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Parker v. Commissioner (T.C. Memo. 2021-111). The primary issues presented in Parker were (1) whether petitioners can deduct, on Schedule C (Profit or Loss From Business), car and truck expenses in excess of the amount

Read More »

Nurumbi v. Commissioner (T.C. Memo. 2021-79)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for

Read More »

Franklin v. Commissioner (T.C. Memo. 2020-127)

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled to deduct

Read More »

Collins v. Commissioner (T.C. Memo. 2020-50)

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 were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the

Read More »

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

Read More »

Near v. Commissioner (T.C. Memo. 2020-10)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when

Read More »

Rivera v. Commissioner (T.C. Memo. 2020-7)

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions

Read More »