Deductions

Olsen v. Commissioner (T.C. Memo. 2021-41)

On April 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Olsen v. Commissioner (T.C. Memo. 2021-41). The primary issues presented in Olsen were whether the petitioners were entitled to depreciation deductions reported on Schedules C (Profit or Loss from Business) and whether they were entitled to energy tax credits reported on Forms 3800 (General Business Credit) for deductions and credits related to a solar energy tax shelter.  Held: Hells no.

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Books and Records

Lucero v. Commissioner (T.C. Memo. 2020-136)

On September 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Lucero v. Commissioner (T.C. Memo. 2020-136). The issue before the court in Lucero was whether the petitioners’ real estate loss deductions were disallowed by IRC § 469 and/or IRC § 280A.

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Burden of Proof

Sellers v. Commissioner (T.C. Memo. 2020-84)

On June 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Sellers v. Commissioner (T.C. Memo. 2020-84). The primary issue before the court in Sellers was whether the petitioner provided sufficient evidence to substantiate his bases in certain companies and his material participation (for passive activity loss purposes). This case also presents a very interesting question of whether the burden of proof really shifts to the IRS to prove additional deficiencies

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Burden of Proof

Hakkak v. Commissioner (T.C. Memo. 2020-46)

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Hakkak v. Commissioner (T.C. Memo. 2020-45). The issue properly before the court in Hakkak was whether petitioners are entitled to treat as nonpassive certain rental real estate losses they previously treated as passive under IRC § 469 on their Schedules E (Supplemental Income and Loss) for the years at issue.

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Olsen v. Commissioner (T.C. Memo. 2021-41)

On April 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Olsen v. Commissioner (T.C. Memo. 2021-41). The primary issues presented in Olsen were whether the petitioners were entitled to depreciation deductions reported on Schedules C (Profit or Loss from Business) and whether they were entitled

Read More »

Lucero v. Commissioner (T.C. Memo. 2020-136)

On September 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Lucero v. Commissioner (T.C. Memo. 2020-136). The issue before the court in Lucero was whether the petitioners’ real estate loss deductions were disallowed by IRC § 469 and/or IRC § 280A.

Read More »

Sellers v. Commissioner (T.C. Memo. 2020-84)

On June 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Sellers v. Commissioner (T.C. Memo. 2020-84). The primary issue before the court in Sellers was whether the petitioner provided sufficient evidence to substantiate his bases in certain companies and his material participation (for passive activity

Read More »

Hakkak v. Commissioner (T.C. Memo. 2020-46)

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Hakkak v. Commissioner (T.C. Memo. 2020-45). The issue properly before the court in Hakkak was whether petitioners are entitled to treat as nonpassive certain rental real estate losses they previously treated as passive under IRC

Read More »