Income Tax Issues
Bank Deposits Analysis

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for filing (very) late and for being (very) negligent and for (very) substantially understating their liabilities. Background to NOLs in Martin v. Commissioner The

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Scott St. Amand March 14, 2021
Business Related Issues
Accuracy Related Penalty

Caylor Land & Development v. Commissioner
T.C. Memo. 2021-30

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30). The primary issues presented in Caylor Land & Development v. Commissioner were whether consulting payments made between the petitioner and its microcaptive insurance company were ordinary and necessary business expenses or insurance expenses. Brief Background (to Lay a Foundation for Judge Holmes’ Puns) in Caylor Land & Development v. Commissioner The

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Scott St. Amand March 10, 2021
Charitable Contributions

Pankratz v. Commissioner
T.C. Memo. 2021-26

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz v. Commissioner was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his tax returns before filing. Introductory Notes: I cannot say for sure whether the return preparers were actually the fire chief and the village

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Scott St. Amand March 3, 2021
Income Tax Issues
Business or Personal Losses

Gallegos v. Commissioner
T.C. Memo. 2021-25

On March 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gallegos v. Commissioner (T.C. Memo. 2021-25). The primary issue presented in Gallegos v. Commissioner was whether the team roping expenses the petitioner claimed on his Schedule C as business losses were business or personal in nature. Giddy-up, ya’ll… Setting the Stage for Gallegos v. Commissioner First, this is a Judge Holmes opinion, so you know it’s going to be gold.

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Scott St. Amand March 2, 2021
Charitable Contributions

Oakbrook Land Holdings LLC v. Commissioner
T.C. Memo. 2020-54

On May 12, 2020, the Tax Court issued its Memorandum Opinion in Oakbrook Land Holdings LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook I) concurrently with a full Tax Court opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook II). The issue presented in Oakbrook Land Holdings LLC v. Commissioner was whether Oakbrook’s conservation easement violated the “protected in perpetuity” requirement of IRC § 170(h)(5), as interpreted in Treas. Reg. § 1.170A-14(g)(6), because the

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Scott St. Amand May 12, 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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Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for

Read More »
Scott St. Amand March 14, 2021

Caylor Land & Development v. Commissioner
T.C. Memo. 2021-30

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30). The primary issues presented in Caylor Land & Development v. Commissioner were whether consulting payments made between the petitioner and its microcaptive insurance company were ordinary

Read More »
Scott St. Amand March 10, 2021

Pankratz v. Commissioner
T.C. Memo. 2021-26

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz v. Commissioner was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not

Read More »
Scott St. Amand March 3, 2021

Gallegos v. Commissioner
T.C. Memo. 2021-25

On March 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gallegos v. Commissioner (T.C. Memo. 2021-25). The primary issue presented in Gallegos v. Commissioner was whether the team roping expenses the petitioner claimed on his Schedule C as business losses were business or personal in

Read More »
Scott St. Amand March 2, 2021

Oakbrook Land Holdings LLC v. Commissioner
T.C. Memo. 2020-54

On May 12, 2020, the Tax Court issued its Memorandum Opinion in Oakbrook Land Holdings LLC v. Commissioner, T.C. Memo. 2020-54 (Oakbrook I) concurrently with a full Tax Court opinion in Oakbrook Land Holdings v. Commissioner, 154 T.C. No. 10 (Oakbrook II). The issue presented in Oakbrook Land Holdings LLC

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Scott St. Amand May 12, 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

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Scott St. Amand January 8, 2020