Income Tax Issues
Bona Fide Residence

Wood v. Commissioner
T.C. Memo. 2021-103

On August 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Wood v. Commissioner (T.C. Memo. 2021-103). The primary issues presented in Wood v. Commissioner were whether the petitioner is entitled to exclude from gross income, as “foreign earned income” under IRC § 911(a)(1), the wages she earned while employed as a contractor on a U.S. military base in Afghanistan; and (2) whether the petitioner is liable for a late-filing penalty

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Scott St. Amand October 2, 2021
International Issues
Foreign Tax Credit

Landrau v. Commissioner
T.C. Memo. 2021-72

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Landrau v. Commissioner (T.C. Memo. 2021-72). The primary issue presented in Landrau was whether the IRS correctly computed their allowable foreign tax credit for 2012. Background to Landrau v. Commissioner During 2014 petitioner-husband received wages of $74,680 for services performed in Puerto Rico for the U.S. Air Force. Petitioner-wife received a pension distribution of $10,380 and U.S. Social Security benefits of

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Scott St. Amand June 21, 2021
Procedural Issues
Closing Agreements as Contracts

Crandall v. Commissioner
T.C. Memo. 2021-39

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Crandall v. Commissioner (T.C. Memo. 2021-39). The primary issue presented in Crandall v. Commissioner was whether the parties’ closing agreement precluded the determined deficiency and penalty. Background to Determination in Crandall v. Commissioner During taxable years 2003 through 2011 the petitioners received foreign-source pension income, interest income, and ordinary dividends. For each of those years they paid Italian income tax. 

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Scott St. Amand March 29, 2021
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Wood v. Commissioner
T.C. Memo. 2021-103

On August 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Wood v. Commissioner (T.C. Memo. 2021-103). The primary issues presented in Wood v. Commissioner were whether the petitioner is entitled to exclude from gross income, as “foreign earned income” under IRC § 911(a)(1), the wages

Read More »
Scott St. Amand October 2, 2021

Landrau v. Commissioner
T.C. Memo. 2021-72

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Landrau v. Commissioner (T.C. Memo. 2021-72). The primary issue presented in Landrau was whether the IRS correctly computed their allowable foreign tax credit for 2012. Background to Landrau v. Commissioner During 2014 petitioner-husband received wages of

Read More »
Scott St. Amand June 21, 2021

Crandall v. Commissioner
T.C. Memo. 2021-39

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Crandall v. Commissioner (T.C. Memo. 2021-39). The primary issue presented in Crandall v. Commissioner was whether the parties’ closing agreement precluded the determined deficiency and penalty. Background to Determination in Crandall v. Commissioner During taxable

Read More »
Scott St. Amand March 29, 2021