Income Tax Issues
Accuracy Related Penalty

Vennes v. Commissioner (T.C. Memo. 2021-93)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty pursuant to IRC § 6662(a). A Checkered Past In 1990, the petitioner completed a prison sentence for money laundering, narcotics, and firearms offenses. After his

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Charitable Contributions

Pankratz v. Commissioner (T.C. Memo. 2021-26)

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his tax returns before filing. Introductory Notes: I cannot say for sure whether the return preparers were actually the fire chief and the village idiot, but

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Vennes v. Commissioner (T.C. Memo. 2021-93)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty

Read More »

Pankratz v. Commissioner (T.C. Memo. 2021-26)

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his

Read More »