Income Tax Issues
Abandonment

Reckless (albeit Tax Conscious) Abandonment under IRC § 165

Uncle Bill is somewhat of a hoarder.  In truth, the only thing that he has ever abandoned was his first wife…in a Waffle House at 2:15 AM on the outskirts of Norman, Oklahoma. In Bill’s defense, she had tried to stab him. In her defense, he probably deserved it. When Bill comes to you to chat about IRC § 165 losses—so-called “abandonment” losses—you know he has some hairbrained scheme in his head to stick it

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Scott St. Amand April 29, 2021
Income Tax Issues
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 to Baum v. Commissioner:

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Scott St. Amand April 27, 2021
Business Related Issues
Accuracy Related Penalty

Filler v. Commissioner
T.C. Memo. 2021-6

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Filler v. Commissioner (T.C. Memo. 2021-6). The issues presented in Filler v. Commissioner were whether the petitioner (1) properly reported $100,000 in income received as capital gain rather than ordinary income; (2) is liable for self-employment tax; (3) is entitled to deduct a net operating loss carryover originating in tax year 2012; and (4) is liable for penalty under IRC

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Scott St. Amand January 13, 2021
Income Tax Issues
Cohan Rule

Coleman v. Commissioner
T.C. Memo. 2020-146

On October 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Coleman v. Commissioner (T.C. Memo. 2020-146). The primary issue before the court in Coleman v. Commissioner was whether the petitioner could substantiate that he sustained a large gambling loss ($350,000).

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Scott St. Amand October 22, 2020
Income Tax Issues
IRC § 165

Giambrone v. Commissioner
T.C. Memo. 2020-145

On October 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Giambrone v. Commissioner (T.C. Memo. 2020-145). The primary issue before the court in Giambrone v. Commissioner is whether the IRS improperly disallowed a theft loss deduction that the petitioners claimed on their respective 2012 returns.

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Scott St. Amand October 19, 2020
Income Tax Issues
Accuracy Related Penalty

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for

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Scott St. Amand April 9, 2020
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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 »
Scott St. Amand April 27, 2021

Filler v. Commissioner
T.C. Memo. 2021-6

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Filler v. Commissioner (T.C. Memo. 2021-6). The issues presented in Filler v. Commissioner were whether the petitioner (1) properly reported $100,000 in income received as capital gain rather than ordinary income; (2) is liable for

Read More »
Scott St. Amand January 13, 2021

Coleman v. Commissioner
T.C. Memo. 2020-146

On October 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Coleman v. Commissioner (T.C. Memo. 2020-146). The primary issue before the court in Coleman v. Commissioner was whether the petitioner could substantiate that he sustained a large gambling loss ($350,000).

Read More »
Scott St. Amand October 22, 2020

Giambrone v. Commissioner
T.C. Memo. 2020-145

On October 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Giambrone v. Commissioner (T.C. Memo. 2020-145). The primary issue before the court in Giambrone v. Commissioner is whether the IRS improperly disallowed a theft loss deduction that the petitioners claimed on their respective 2012 returns.

Read More »
Scott St. Amand October 19, 2020

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue;

Read More »
Scott St. Amand April 9, 2020