IRC § 262 Archives | Briefly Taxing

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

Scott St. Amand May 4, 2021

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

Scott St. Amand April 29, 2021

IRC § 162

Brashear v. Commissioner
T.C. Memo. 2020-122

On August 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Brashear v. Commissioner (T.C. Memo. 2020-122). The primary issue before the court in Brashear was whether the petitioners were entitled to various deductions on Schedule C (Profits and Loss from Business). Business-Related Deductions 101 in Brashear v. Commissioner The taxpayer’s burden of proof regarding entitlement to deductions requires the taxpayer to substantiate all expenses underlying the deductions claimed by keeping

Scott St. Amand August 19, 2020

Deductibility of Expenses

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses in General as explained by Christensen v. Commissioner Because deductions are a “matter of legislative grace,” taxpayers bear the burden of establishing their entitlement thereto.

Scott St. Amand January 15, 2020