Business Related Issues
Computer Software

BATS Global Markets Holdings Inc. v. Commissioner
158 T.C. No. 5

On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner’s transaction fees, routing fees, and logical port fees qualify as domestic production gross receipts (DPGR) for the purpose of calculating deductions pursuant to IRC § 199. Held: No dice, BATS. Procedural Background to BATS Global Markets

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Scott St. Amand June 13, 2022
Business Related Issues
C Corporations

Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v. Commissioner I find the petitioner suspect.  First off, it is an Iowa C corporation, but it is not involved with the production or processing of

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Scott St. Amand January 21, 2021
Income Tax Issues
Computer Software

TGS-NOPEC Geophysical Company v. Commissioner
155 T.C. No. 3

On August 26, 2020, the Tax Court issued its opinion in TGS-NOPEC Geophysical Company v. Commissioner (155 T.C. No. 3). The primary issue presented in TGS-NOPEC Geophysical Company v. Commissioner is whether the IRS’s disallowance of petitioner’s deduction for income attributable to domestic production activities pursuant to IRC § 199 was appropriate. Business Background in TGS-NOPEC Geophysical Company v. Commissioner The petitioner is engaged in the business of acquires, processes, and licenses marine seismic data. Raw

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Scott St. Amand August 26, 2020
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BATS Global Markets Holdings Inc. v. Commissioner
158 T.C. No. 5

On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner’s transaction fees, routing fees, and logical port fees qualify as domestic

Read More »
Scott St. Amand June 13, 2022

Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v.

Read More »
Scott St. Amand January 21, 2021

TGS-NOPEC Geophysical Company v. Commissioner
155 T.C. No. 3

On August 26, 2020, the Tax Court issued its opinion in TGS-NOPEC Geophysical Company v. Commissioner (155 T.C. No. 3). The primary issue presented in TGS-NOPEC Geophysical Company v. Commissioner is whether the IRS’s disallowance of petitioner’s deduction for income attributable to domestic production activities pursuant to IRC § 199 was

Read More »
Scott St. Amand August 26, 2020