Procedural Issues
Filing Date

Procedures for Signing and Filing Returns

So, you have to file a tax return. Congratulations. Throw on your grown-up pants, and let’s look at when returns are due, signing of the returns, extensions of time for filing returns, and where to file the returns – all of which are contained in Subchapter A of the Code. If you need a refresher on what makes a return satisfactory to the IRS, check out the article “What is a Return, and When is

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Scott St. Amand April 29, 2021
Income Tax Issues
Deathbed Transfers

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate and (2) whether the petitioner’s estate planning resulted in unintended taxable gifts. The Tax Court answers these questions through a most thorough analysis of IRC

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Scott St. Amand April 7, 2020
Income Tax Issues
Admissibility of Evidence

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner from a GRAT and an irrevocable trust, respectively. Background to Grieve v. Commissioner – A Three Hour Tour This is the cautionary tale

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Scott St. Amand March 2, 2020
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Procedures for Signing and Filing Returns

So, you have to file a tax return. Congratulations. Throw on your grown-up pants, and let’s look at when returns are due, signing of the returns, extensions of time for filing returns, and where to file the returns – all of which are contained in Subchapter A of the Code.

Read More »
Scott St. Amand April 29, 2021

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate

Read More »
Scott St. Amand April 7, 2020

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to

Read More »
Scott St. Amand March 2, 2020