Income Tax Issues
Hobby Losses under IRC § 183

Huff v. Commissioner
T.C. Memo. 2021-140

On December 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Huff v. Commissioner (T.C. Memo. 2021-140). The primary issue presented in Huff was whether the petitioners’ miniature donkey breeding operation was an activity engaged in for profit within the meaning of IRC § 183. Held: Actually, yes. Author’s Note on Huff v. Commissioner Judge Patrick J. Urda (who delivered this opinion) was a Classics major at Notre Dame, where he

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Scott St. Amand April 26, 2022
Income Tax Issues
Books and Records

Chancellor v. Commissioner
T.C. Memo. 2021-50

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor v. Commissioner was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local tax. Brief Background to Chancellor v. Commissioner Ms. Viola Chancellor, of Nevada, is a notary and a paralegal.  In 2015, she received $400 from her

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Scott St. Amand May 4, 2021
Income Tax Issues
Capital Expenditures

Deducting Legal and Professional Fees

Income tax deductions are rather like hard truths. A client may not want to hear that an item is not deductible, but you know in your heart of hearts that you cannot, in good conscience, advise them otherwise. No doctor relishes the prospect of telling a patient that he is terminal. Often met with a similar grief-stricken reaction, explaining to a client that the “big ticket” deduction that they wanted to claim (or in my

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Scott St. Amand April 29, 2021
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Huff v. Commissioner
T.C. Memo. 2021-140

On December 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Huff v. Commissioner (T.C. Memo. 2021-140). The primary issue presented in Huff was whether the petitioners’ miniature donkey breeding operation was an activity engaged in for profit within the meaning of IRC § 183. Held:

Read More »
Scott St. Amand April 26, 2022

Chancellor v. Commissioner
T.C. Memo. 2021-50

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor v. Commissioner was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local

Read More »
Scott St. Amand May 4, 2021

Deducting Legal and Professional Fees

Income tax deductions are rather like hard truths. A client may not want to hear that an item is not deductible, but you know in your heart of hearts that you cannot, in good conscience, advise them otherwise. No doctor relishes the prospect of telling a patient that he is

Read More »
Scott St. Amand April 29, 2021