IRC § 61 Archives | Briefly Taxing

Contingent Fees

Holliday v. Commissioner (T.C. Memo. 2021-69)

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background Two lawsuits are central to this case. The first is petitioner’s divorce proceeding, in which she was represented by J. Beverly and his law firm (divorce attorney and malpractice defendants, respectively). The second is petitioner’s malpractice

Scott St. Amand June 21, 2021

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

Scott St. Amand May 21, 2021

Bank Deposits Analysis

Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47)

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context This is an unreported income case, and the opinion is all of six pages long. One has expectations of a couple thousand dollars-worth of unreported income. But not

Scott St. Amand April 29, 2021