Penalties Under the Code
IRC § 6901

Alta V Limited Partnership v. Commissioner
T.C. Memo. 2020-8

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed deficiency, penalties, and additions to tax with respect to the transferor’s corporate income tax. Transferee Liability Under the Code – IRC § 6901(a) – Alta

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Scott St. Amand January 13, 2020
Income Tax Issues
Accuracy Related Penalty

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

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Scott St. Amand January 13, 2020
Business Related Issues
Abuse of Discretion

Hommel v. Commissioner
T.C. Memo. 2020-4

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel v. Commissioner was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue, however, was how close Judge Holmes could get to calling the petitioner a #^&%$ idiot without actually doing so. Personal Note in Hommel

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Scott St. Amand January 8, 2020
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Alta V Limited Partnership v. Commissioner
T.C. Memo. 2020-8

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed

Read More »
Scott St. Amand January 13, 2020

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to

Read More »
Scott St. Amand January 13, 2020

Hommel v. Commissioner
T.C. Memo. 2020-4

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel v. Commissioner was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The

Read More »
Scott St. Amand January 8, 2020