Appeals

Mason v. Commissioner (T.C. Memo. 2021-64)

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason was whether Appeals abused its discretion by reviewing the Centralized Unit’s decision for abuse of discretion instead of reviewing the Masons’ offer on its merits. Background: A Lesson in Bureaucracy Victor and Katherine Mason owed back taxes. They didn’t deny it, but they said they didn’t have the

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Burden of Proof

Berry v. Commissioner (T.C. Memo. 2021-42)

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether the petitioners are entitled to certain claimed deductions, and whether the petitioners are liable for accuracy-related penalties under IRC § 6662. Background In 2013, Ronald Berry and

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Abuse of Discretion

Smith v. Commissioner (T.C. Memo. 2021-29)

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner expects the IRS to act in making a refund, purports to be a return of income tax, and whether the petitioner was liable for the IRC §

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Form 4549

Beland v. Commissioner (156 T.C. No. 5)

On March 1, 2021, the Tax Court issued its opinion in Beland v. Commissioner, 156 T.C. No. 5. The underlying issue presented in Beland was whether the civil fraud penalty was not timely approved pursuant to IRC § 6751(b)(1). Background The petitioners filed a joint return for 2011.  The IRS audited the return and required the petitioners to attend an in-person closing conference.  During the conference, the revenue agent presented the petitioners with a completed,

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Dammit Felicia

Mathews v. Commissioner (T.C. Memo. 2021-28)

On March 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-28). The primary issue presented in Mathews was whether the petitioner was entitled to car and truck expenses which were incurred driving from his residence to the location of his employer, a trucking company. General Rule As a general rule, expenses for traveling between one’s home and one’s place of business or employment are commuting

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Cash Equivalence Doctrine

Anikeev v. Commissioner (T.C. Memo. 2021-23)

On February 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Anikeev v. Commissioner (T.C. Memo. 2021-23). The primary issue presented in Anikeev was whether the “rewards” earned from the purchase of gift cards…a lot of gift cards…were income. Background The petitioners were crafty Russians, who gamed the credit card reward system.  They joined a credit card rewards program and proceeded to purchase their credit limit worth of prepaid gift cards. 

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Accuracy Related Penalty

Sells v. Commissioner (T.C. Memo. 2021-12)

On January 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Sells v. Commissioner (T.C. Memo. 2021-12). The main issue presented in Sells was whether the conservation easement deduction was appropriately denied, but it is the prior supervisory approval that we’ll focus on below. Background to the Penalty Issue The IRS asserted penalties for both the conservation easement and the timber donation. However, the parties stipulated that the IRS had a

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Mason v. Commissioner (T.C. Memo. 2021-64)

On May 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Mason v. Commissioner (T.C. Memo. 2021-64). The primary issue presented in Mason was whether Appeals abused its discretion by reviewing the Centralized Unit’s decision for abuse of discretion instead of reviewing the Masons’ offer on

Read More »

Berry v. Commissioner (T.C. Memo. 2021-42)

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether the petitioners

Read More »

Smith v. Commissioner (T.C. Memo. 2021-29)

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner expects the

Read More »

Beland v. Commissioner (156 T.C. No. 5)

On March 1, 2021, the Tax Court issued its opinion in Beland v. Commissioner, 156 T.C. No. 5. The underlying issue presented in Beland was whether the civil fraud penalty was not timely approved pursuant to IRC § 6751(b)(1). Background The petitioners filed a joint return for 2011.  The IRS

Read More »

Mathews v. Commissioner (T.C. Memo. 2021-28)

On March 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-28). The primary issue presented in Mathews was whether the petitioner was entitled to car and truck expenses which were incurred driving from his residence to the location of his

Read More »

Anikeev v. Commissioner (T.C. Memo. 2021-23)

On February 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Anikeev v. Commissioner (T.C. Memo. 2021-23). The primary issue presented in Anikeev was whether the “rewards” earned from the purchase of gift cards…a lot of gift cards…were income. Background The petitioners were crafty Russians, who

Read More »

Sells v. Commissioner (T.C. Memo. 2021-12)

On January 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Sells v. Commissioner (T.C. Memo. 2021-12). The main issue presented in Sells was whether the conservation easement deduction was appropriately denied, but it is the prior supervisory approval that we’ll focus on below. Background to

Read More »