Income Tax Issues
Accuracy Related Penalty

Villanueva v. Commissioner
T.C. Memo. 2022-27

On March 31, 2022, the Tax Court issued a Memorandum Opinion in the case of Villanueva v. Commissioner (T.C. Memo. 2022-27). The primary issue presented in Villanueva v. Commissioner was whether the petitioner was entitled to a net operating loss deduction. Held: Sorry, Edgardo, not today. Background to Villanueva v. Commissioner The IRS determined deficiencies against the petitioner for 2013 and 2014 of $61,832 and $90,408, respectively, and an IRC § 6662(a) accuracy-related penalty and

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Scott St. Amand November 21, 2022
Penalties Under the Code
IRC § 6662

Oxbow Bend LLC v. Commissioner
T.C. Memo. 2022-23

On March 21, 2022, the Tax Court issued a Memorandum Opinion in the case of Oxbow Bend LLC v. Commissioner (T.C. Memo. 2022-23). The primary issue presented in Oxbow Bend LLC v. Commissioner was whether a telephone conference in which IRS agent stated to taxpayer’s representative what adjustments would be made and what penalties were under consideration constituted an “initial determination” of penalties that would require timely supervisory approval under IRC § 6751(b)(1). Held: Not

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Scott St. Amand November 15, 2022
Accuracy Related Penalty

Pickens Decorative Stone LLC v. Commissioner
T.C. Memo. 2022-22

On March 17, 2022, the Tax Court issued a Memorandum Opinion in the case of Pickens Decorative Stone LLC v. Commissioner (T.C. Memo. 2022-22). The primary issues presented in Pickens Decorative Stone LLC v. Commissioner were (1) whether the taxpayer was entitled to qualified charitable contribution deduction for claimed easement, and (2) whether the IRS revenue agent secured timely supervisory approval from supervisor, as required for imposition of accuracy-related penalties due to substantial understatement of

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Scott St. Amand November 14, 2022
Penalties Under the Code
Accuracy Related Penalty

Soni v. Commissioner
T.C. Memo. 2021-137

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Soni v. Commissioner (T.C. Memo. 2021-137). The primary issues presented in Soni were (1) whether the petitioners filed a valid joint return; (2) whether the period of limitations for assessment of tax under IRC § 6501(a) and (c)(4) expired before the issuance of the notice of deficiency; (3) whether the petitioners are liable for an addition to tax under IRC

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Scott St. Amand April 23, 2022
Penalties Under the Code
Accuracy Related Penalty

Plateau Holdings LLC v. Commissioner
T.C. Memo. 2021-133

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Plateau Holdings LLC v. Commissioner (T.C. Memo. 2021-133). The primary issue presented in Plateau Holdings LLC was whether the 20% accuracy-related penalty applied to the portion of the underpayment not attributable to a valuation misstatement, that is, to the portion of the underpayment resulting from the Tax Court’s conclusion that the petitioner was not entitled to a charitable contribution deduction

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Scott St. Amand April 19, 2022
Income Tax Issues
Accuracy Related Penalty

Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay advance premium tax credit (APTC) payments of the PTC. Held: Yup and yeppers. Background to Knox v. Commissioner The petitioners were (and perhaps still are)

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Scott St. Amand March 30, 2022
Penalties Under the Code
Initial Determination of Penalties

Excelsior Aggregates v. Commissioner
T.C. Memo. 2021-125

On November 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Excelsior Aggregates v. Commissioner (T.C. Memo. 2021-125). The primary issue presented in Excelsior Aggregates was whether the IRS complied with the prior supervisory approval requirement of IRC § 6751(b)(1) with respect to the numerous penalties asserted against the petitioner (IRC § 6662A and IRC § 6662(a), (b)(1)-(3), (d), (e), and (h)). Held: Executive Summary from the Tax Court in Excelsior

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Scott St. Amand March 29, 2022
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Villanueva v. Commissioner
T.C. Memo. 2022-27

On March 31, 2022, the Tax Court issued a Memorandum Opinion in the case of Villanueva v. Commissioner (T.C. Memo. 2022-27). The primary issue presented in Villanueva v. Commissioner was whether the petitioner was entitled to a net operating loss deduction. Held: Sorry, Edgardo, not today. Background to Villanueva v.

Read More »
Scott St. Amand November 21, 2022

Oxbow Bend LLC v. Commissioner
T.C. Memo. 2022-23

On March 21, 2022, the Tax Court issued a Memorandum Opinion in the case of Oxbow Bend LLC v. Commissioner (T.C. Memo. 2022-23). The primary issue presented in Oxbow Bend LLC v. Commissioner was whether a telephone conference in which IRS agent stated to taxpayer’s representative what adjustments would be

Read More »
Scott St. Amand November 15, 2022

Pickens Decorative Stone LLC v. Commissioner
T.C. Memo. 2022-22

On March 17, 2022, the Tax Court issued a Memorandum Opinion in the case of Pickens Decorative Stone LLC v. Commissioner (T.C. Memo. 2022-22). The primary issues presented in Pickens Decorative Stone LLC v. Commissioner were (1) whether the taxpayer was entitled to qualified charitable contribution deduction for claimed easement,

Read More »
Scott St. Amand November 14, 2022

Soni v. Commissioner
T.C. Memo. 2021-137

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Soni v. Commissioner (T.C. Memo. 2021-137). The primary issues presented in Soni were (1) whether the petitioners filed a valid joint return; (2) whether the period of limitations for assessment of tax under IRC §

Read More »
Scott St. Amand April 23, 2022

Plateau Holdings LLC v. Commissioner
T.C. Memo. 2021-133

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Plateau Holdings LLC v. Commissioner (T.C. Memo. 2021-133). The primary issue presented in Plateau Holdings LLC was whether the 20% accuracy-related penalty applied to the portion of the underpayment not attributable to a valuation misstatement,

Read More »
Scott St. Amand April 19, 2022

Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay

Read More »
Scott St. Amand March 30, 2022

Excelsior Aggregates v. Commissioner
T.C. Memo. 2021-125

On November 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Excelsior Aggregates v. Commissioner (T.C. Memo. 2021-125). The primary issue presented in Excelsior Aggregates was whether the IRS complied with the prior supervisory approval requirement of IRC § 6751(b)(1) with respect to the numerous penalties

Read More »
Scott St. Amand March 29, 2022