Income Tax Issues
Income

Hussey v. Commissioner
156 T.C. No. 12

On June 24, 2021, the Tax Court issued its opinion in Hussey v. Commissioner (156 T.C. No. 12). The primary issues presented in Hussey v. Commissioner were whether the petitioner was required to reduce his bases in disposed depreciable real properties immediately before sales of those properties in year of discharge of qualified real property business indebtedness (QRPBI), rather than in subsequent year; whether the taxpayer had discharge of indebtedness income; and whether the taxpayer

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Income Tax Issues
Frivolous

Delgado v. Commissioner
T.C. Memo. 2021-84

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado v. Commissioner was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade or business” as defined by IRC § 7701(a)(26) held any water… Quick Work of the Frivolousness in Delgado v. Commissioner Compensation for services

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Income Tax Issues
Deductions

Geiman v. Commissioner
T.C. Memo. 2021-80

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman v. Commissioner was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background to Geiman v. Commissioner The petitioner is a union electrician who spent most of 2013 on jobs in various parts of Wyoming and Colorado.

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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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Hussey v. Commissioner
156 T.C. No. 12

On June 24, 2021, the Tax Court issued its opinion in Hussey v. Commissioner (156 T.C. No. 12). The primary issues presented in Hussey v. Commissioner were whether the petitioner was required to reduce his bases in disposed depreciable real properties immediately before sales of those properties in year of

Read More »

Delgado v. Commissioner
T.C. Memo. 2021-84

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado v. Commissioner was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in

Read More »

Geiman v. Commissioner
T.C. Memo. 2021-80

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman v. Commissioner was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses.

Read More »

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 »