Income Tax Issues
Business or Personal Losses

Gallegos v. Commissioner
T.C. Memo. 2021-25

On March 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gallegos v. Commissioner (T.C. Memo. 2021-25). The primary issue presented in Gallegos v. Commissioner was whether the team roping expenses the petitioner claimed on his Schedule C as business losses were business or personal in nature. Giddy-up, ya’ll… Setting the Stage for Gallegos v. Commissioner First, this is a Judge Holmes opinion, so you know it’s going to be gold.

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Scott St. Amand March 2, 2021
Business Related Issues
Activity Engaged in for Profit

Whatley v. Commissioner
T.C. Memo. 2021-11

On January 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Whatley v. Commissioner (T.C. Memo. 2021-11). The issue presented in Whatley v. Commissioner was whether the petitioner’s tree or cattle farm (he can’t seem to decide which) was a trade or business during the years at issue. A Note on my Favorite Jurist, Judge Holmes The opinion begins by describing the petitioner as “a proud Auburn alumnus” who made the

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Scott St. Amand January 28, 2021
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Gallegos v. Commissioner
T.C. Memo. 2021-25

On March 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gallegos v. Commissioner (T.C. Memo. 2021-25). The primary issue presented in Gallegos v. Commissioner was whether the team roping expenses the petitioner claimed on his Schedule C as business losses were business or personal in

Read More »
Scott St. Amand March 2, 2021

Whatley v. Commissioner
T.C. Memo. 2021-11

On January 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Whatley v. Commissioner (T.C. Memo. 2021-11). The issue presented in Whatley v. Commissioner was whether the petitioner’s tree or cattle farm (he can’t seem to decide which) was a trade or business during the years

Read More »
Scott St. Amand January 28, 2021