Income Tax Issues
Deductions

Estate of Morgan v. Commissioner
T.C. Memo. 2021-104

On August 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morgan v. Commissioner (T.C. Memo. 2021-104). The primary issues presented in Estate of Morgan were whether the petitioners (1) are entitled to deductions claimed on Schedule C for expenses incurred by Falcon, LLC (Falcon), and Falcon Legacy, LLC (Legacy); (2) are entitled to a net operating loss deduction attributable to an alleged NOL carryover from tax years 2010

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Scott St. Amand October 3, 2021
Income Tax Issues
Deductions

Geiman v. Commissioner
T.C. Memo. 2021-80

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman v. Commissioner was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background to Geiman v. Commissioner The petitioner is a union electrician who spent most of 2013 on jobs in various parts of Wyoming and Colorado.

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Scott St. Amand July 12, 2021
Income Tax Issues
Deductions

Nurumbi v. Commissioner
T.C. Memo. 2021-79

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi v. Commissioner was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for vehicles for hire applied. Held:  Background to Nurumbi v. Commissioner The petitioner was an Uber pimp. He maintained a stable of Uber drivers

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Scott St. Amand July 12, 2021
Business Related Issues
Capitalization

Mylan Inc. v. Commissioner (156 T.C. No. 10)

On April 27, 2021, the Tax Court issued its opinion in Mylan Inc. v. Commissioner (156 T.C. No. 10). The underlying issues presented in Mylan Inc. v. Commissioner were (1) whether the legal expenses incurred in preparing notice letters to brand name drug companies of petitioner’s intent to make generic versions of its drugs as part of the FDA approval process to do the same were capital or ordinary expenses; and (2) whether the legal expenses

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Scott St. Amand June 20, 2021
Income Tax Issues
Books and Records

Adler v. Commissioner
T.C. Memo. 2021-56

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Adler v. Commissioner (T.C. Memo. 2021-56). The primary issue presented in Adler v. Commissioner was whether the petitioner was entitled to deduct business expenses for 2016 and 2017 (the years in issue). Adler v. Commissioner In Short The petitioner was a consultant for an entertainment company in Los Angeles.  He incurred business-related expenses, including travel expenses, and he reported these

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Scott St. Amand May 10, 2021
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

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Scott St. Amand May 5, 2021
Procedural Issues
Burden of Proof

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule 231. A Lawyer, Scholar, and Author in Jacobs v. Commissioner The petitioner was a trial lawyer with the Department of Justice for 20 years before

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Scott St. Amand May 5, 2021
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Estate of Morgan v. Commissioner
T.C. Memo. 2021-104

On August 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Morgan v. Commissioner (T.C. Memo. 2021-104). The primary issues presented in Estate of Morgan were whether the petitioners (1) are entitled to deductions claimed on Schedule C for expenses incurred by Falcon, LLC

Read More »
Scott St. Amand October 3, 2021

Geiman v. Commissioner
T.C. Memo. 2021-80

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman v. Commissioner was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses.

Read More »
Scott St. Amand July 12, 2021

Nurumbi v. Commissioner
T.C. Memo. 2021-79

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi v. Commissioner was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such

Read More »
Scott St. Amand July 12, 2021

Mylan Inc. v. Commissioner (156 T.C. No. 10)

On April 27, 2021, the Tax Court issued its opinion in Mylan Inc. v. Commissioner (156 T.C. No. 10). The underlying issues presented in Mylan Inc. v. Commissioner were (1) whether the legal expenses incurred in preparing notice letters to brand name drug companies of petitioner’s intent to make generic versions

Read More »
Scott St. Amand June 20, 2021

Adler v. Commissioner
T.C. Memo. 2021-56

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Adler v. Commissioner (T.C. Memo. 2021-56). The primary issue presented in Adler v. Commissioner was whether the petitioner was entitled to deduct business expenses for 2016 and 2017 (the years in issue). Adler v. Commissioner

Read More »
Scott St. Amand May 10, 2021

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

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule

Read More »
Scott St. Amand May 5, 2021