Taxing, Briefly
1099-K

Donation-Based Crowdfunding

Background to Donation-Based Crowdfunding You’ve seen it on Facebook countless times. A tragedy occurs to a friend of a friend, and your (first level) friend sets up a GoFundMe page to raise money for the poor unfortunate souls. An old friend approached me not too long ago. Her brother needed an organ transplant, but because he majored in circus at Florida State (no joke…well, a circus major is, itself, a joke), her brother had no

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Scott St. Amand November 3, 2021
Taxing, Briefly
Accessions to Wealth

Taxing Social Media Influencers – Taxing, Briefly

Harsh Truths Taxing social media influencers? Way harsh, we know. Influencers have it tough anyhow, what with having to photograph everything they eat, or wear, or sneeze on.  Nevertheless, your fearless editors at Briefly Taxing thought it prudent to discuss some harsh truths about getting your money for nothing (and your “gifts” for free)—just in case you were thinking about getting into the social media influencing gambit. In this post, we won’t cast aspersions against

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Scott St. Amand May 21, 2021
Income Tax Issues
Estate Tax

Nelson v. Commissioner
T.C. Memo. 2020-81

On June 10, 2020, the Tax Court issued a Memorandum Opinion in the case of Nelson v. Commissioner (T.C. Memo. 2020-81). The primary issue before the court in Nelson v. Commissioner was whether the limited partnership interests, transferred on December 31, 2008, and January 2, 2009, were fixed dollar amounts or percentage interests, which in turn affected whether the gifts were complete when transferred, which in turn affected inclusion on the petitioners’ income tax returns

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Scott St. Amand June 10, 2020
Income Tax Issues
Burden of Proof

Kroner v. Commissioner
T.C. Memo. 2020-73

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Kroner v. Commissioner (T.C. Memo. 2020-73). The issues before the court in Kroner v. Commissioner were (1) whether transfers of funds to petitioner during the years at issue constitute gifts that petitioner properly excluded from gross income under IRC § 102 and (2) whether petitioner is liable for accuracy-related penalties under IRC § 6662. How Many Kroners does it Take

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Scott St. Amand June 1, 2020
Income Tax Issues
Expectation of Repayment

Estate of Bolles v. Commissioner
T.C. Memo. 2020-71

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Bolles v. Commissioner (T.C. Memo. 2020-71). The sole issue before the court in Estate of Bolles v. Commissioner was whether the transfers from the decedent, Mary Bolles, to her son Peter, which transfers aggregated over $1m, should be treated as loans or gifts. According to the Tax Court, “Each side sees the answer as totally one way. We disagree

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Scott St. Amand June 1, 2020
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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Donation-Based Crowdfunding

Background to Donation-Based Crowdfunding You’ve seen it on Facebook countless times. A tragedy occurs to a friend of a friend, and your (first level) friend sets up a GoFundMe page to raise money for the poor unfortunate souls. An old friend approached me not too long ago. Her brother needed

Read More »
Scott St. Amand November 3, 2021

Taxing Social Media Influencers – Taxing, Briefly

Harsh Truths Taxing social media influencers? Way harsh, we know. Influencers have it tough anyhow, what with having to photograph everything they eat, or wear, or sneeze on.  Nevertheless, your fearless editors at Briefly Taxing thought it prudent to discuss some harsh truths about getting your money for nothing (and

Read More »
Scott St. Amand May 21, 2021

Nelson v. Commissioner
T.C. Memo. 2020-81

On June 10, 2020, the Tax Court issued a Memorandum Opinion in the case of Nelson v. Commissioner (T.C. Memo. 2020-81). The primary issue before the court in Nelson v. Commissioner was whether the limited partnership interests, transferred on December 31, 2008, and January 2, 2009, were fixed dollar amounts

Read More »
Scott St. Amand June 10, 2020

Kroner v. Commissioner
T.C. Memo. 2020-73

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Kroner v. Commissioner (T.C. Memo. 2020-73). The issues before the court in Kroner v. Commissioner were (1) whether transfers of funds to petitioner during the years at issue constitute gifts that petitioner properly excluded from

Read More »
Scott St. Amand June 1, 2020

Estate of Bolles v. Commissioner
T.C. Memo. 2020-71

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Bolles v. Commissioner (T.C. Memo. 2020-71). The sole issue before the court in Estate of Bolles v. Commissioner was whether the transfers from the decedent, Mary Bolles, to her son Peter, which transfers aggregated

Read More »
Scott St. Amand June 1, 2020

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