Income Tax Issues
Additional Tax

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied; and (ii) whether the taxpayer was entitled to itemized deductions when he failed to file a return, and the IRS filed a substitute for return

Read More »
Scott St. Amand November 23, 2022
Income Tax Issues
Books and Records

Avoiding the Net Investment Income Tax with Significant Participation

Uncle Bill’s Net Investment Income Tax Quandary Suffice it to say that Uncle Bill had a good year in 2021. As you may remember from this article, Bill and Ethel’s daughter Moon (neé Jaime) was one of the initial investors in a small online book retailer based out of Seattle that was founded by her friend Jeff. When the website took off, Moon made a pretty penny (or 304 billion pretty pennies). Bill invested a

Read More »
Scott St. Amand March 29, 2022
Income Tax Issues
Accuracy Related Penalty

Berry v. Commissioner
T.C. Memo. 2021-52

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry v. Commissioner were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is entitled to deduct racecar expenses, and whether or not the petitioners substantiated COGS or a depreciation deduction under IRC § 167(a). Background to Berry

Read More »
Scott St. Amand May 5, 2021
Income Tax Issues
Books and Records

Chancellor v. Commissioner
T.C. Memo. 2021-50

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor v. Commissioner was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local tax. Brief Background to Chancellor v. Commissioner Ms. Viola Chancellor, of Nevada, is a notary and a paralegal.  In 2015, she received $400 from her

Read More »
Scott St. Amand May 4, 2021
Procedural Issues
Books and Records

The Record Keeping Requirement of IRC § 6001

Uncle Bill has gotten somewhat of a large bee in his bonnet (a murder hornet of sorts, if you want to know the truth), and he has asked you to teach him everything that you know about civil tax procedure. You note that you are far too busy with your burgeoning practice, but you are intrigued by the Ol’ Codger’s desire to learn the ins and outs of the process through which the IRS collects

Read More »
Scott St. Amand April 29, 2021
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

Read More »
Scott St. Amand November 23, 2022

Berry v. Commissioner
T.C. Memo. 2021-52

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry v. Commissioner were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company

Read More »
Scott St. Amand May 5, 2021

Chancellor v. Commissioner
T.C. Memo. 2021-50

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor v. Commissioner was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local

Read More »
Scott St. Amand May 4, 2021

The Record Keeping Requirement of IRC § 6001

Uncle Bill has gotten somewhat of a large bee in his bonnet (a murder hornet of sorts, if you want to know the truth), and he has asked you to teach him everything that you know about civil tax procedure. You note that you are far too busy with your

Read More »
Scott St. Amand April 29, 2021