Estate Tax

Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60)

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60). The primary issue presented in Estate of Morrissette was whether IRC § 2036 or IRC § 2038 applies to recapture significant inter vivos transfers made as part of the split-dollar agreements, and, if not, whether the special valuation rule of IRC § 2703 applies to require that the valuation disregard a provision

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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 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 You may remember

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Accuracy Related Penalty

Baum v. Commissioner (T.C. Memo. 2021-46)

On April 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Baum v. Commissioner (T.C. Memo. 2021-46). The primary issues presented in Baum were whether the petitioners were entitled to deductions for expenses as reported on Schedules C (Profit or Loss from Business) for the years in issue and whether the petitioners were entitled to a theft loss deduction pursuant to IRC § 165 for 2015. Background: Bamboozled, Hoodwinked, Swindled, and

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Accuracy Related Penalty

Plentywood Drug, Inc. v. Commissioner (T.C. Memo. 2021-45)

On April 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Plentywood Drug, Inc. v. Commissioner (T.C. Memo. 2021-45). The primary issues presented in Plentywood Drug, Inc. were whether the petitioner’s owners received “fair rent” or constructive dividends for the rental of the petitioner’s drug store, and whether the petitioner (a corporation) satisfied its burden to show that the IRS failed to receive prior supervisory approval for the accuracy-related penalties at

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Accuracy Related Penalty

Walton v. Commissioner (T.C. Memo. 2021-40)

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background The petitioner was a New Yorker,[1] who failed to report $170,000 in nonemployee compensation in 2015. Strike one and two. The petitioner was terminated from her employment, and negotiated a

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Accuracy Related Penalty

Purple Heart Patient Center, Inc. v. Commissioner (T.C. Memo. 2021-38)

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Purple Heart Patient Center, Inc. v. Commissioner (T.C. Memo. 2021-38). The primary issues presented in Purple Heart Patient Center were whether the petitioner (1) was entitled to offset its gross receipts with any cost of goods sold (COGS), (2) underreported its gross income, and (3) is liable for the accuracy-related penalty pursuant to IRC § 6662(a). Background Purple Heart is

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Accuracy Related Penalty

Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30)

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30). The primary issues presented in Caylor Land & Development were whether consulting payments made between the petitioner and its microcaptive insurance company were ordinary and necessary business expenses or insurance expenses. Brief Background (to Lay a Foundation for Judge Holmes’ Puns) The Caylors, Bob and Rob, founded and kept afloat, a

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Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60)

On May 12, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morrissette v. Commissioner (T.C. Memo. 2021-60). The primary issue presented in Estate of Morrissette was whether IRC § 2036 or IRC § 2038 applies to recapture significant inter vivos transfers made as part

Read More »

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 were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is

Read More »

Baum v. Commissioner (T.C. Memo. 2021-46)

On April 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Baum v. Commissioner (T.C. Memo. 2021-46). The primary issues presented in Baum were whether the petitioners were entitled to deductions for expenses as reported on Schedules C (Profit or Loss from Business) for the years

Read More »

Plentywood Drug, Inc. v. Commissioner (T.C. Memo. 2021-45)

On April 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Plentywood Drug, Inc. v. Commissioner (T.C. Memo. 2021-45). The primary issues presented in Plentywood Drug, Inc. were whether the petitioner’s owners received “fair rent” or constructive dividends for the rental of the petitioner’s drug store,

Read More »

Walton v. Commissioner (T.C. Memo. 2021-40)

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background The petitioner was a New

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Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30)

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30). The primary issues presented in Caylor Land & Development were whether consulting payments made between the petitioner and its microcaptive insurance company were ordinary and necessary

Read More »