Income Tax Issues
Agency Receipt Doctrine

Understanding the Doctrine of Constructive Receipt

Uncle Bill Sells the Buick Your dear Uncle Bill calls you all in a tizzy asking for some (free) legal advice from his “favorite” nephew. You want to remind him that you are (a) the only lawyer in the family, and (b) the only one of his nephews who not currently in the hoosegow, but you think better of it and indulge him. Bill and Aunt Ethel, who apparently are back together after the Thanksgiving

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Scott St. Amand April 30, 2021
Penalties Under the Code
Burden of Proof

Isaacson v. Commissioner
T.C. Memo. 2020-17

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson v. Commissioner were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore, liable for the civil fraud penalty under IRC § 6663. Background to Isaacson v. Commissioner The petitioner, a trial attorney, who specialized in (among other

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Scott St. Amand January 23, 2020
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Understanding the Doctrine of Constructive Receipt

Uncle Bill Sells the Buick Your dear Uncle Bill calls you all in a tizzy asking for some (free) legal advice from his “favorite” nephew. You want to remind him that you are (a) the only lawyer in the family, and (b) the only one of his nephews who not

Read More »
Scott St. Amand April 30, 2021

Isaacson v. Commissioner
T.C. Memo. 2020-17

On January 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Isaacson v. Commissioner (T.C. Memo. 2020-17). The issues presented in Isaacson v. Commissioner were whether the petitioner (1) failed to report taxable income for tax year 2007, and (2) if so, was the petitioner, therefore,

Read More »
Scott St. Amand January 23, 2020