Procedural Issues
Bad Debt Deductions

Kelly v. Commissioner
T.C. Memo. 2021-76

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly v. Commissioner were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or cancellation of indebtedness (COD) income when the loans were cancelled. Background to Kelly v. Commissioner The petitioner was a 50% owner of Lucky Bastard Records.

Read More »
Scott St. Amand July 12, 2021
Business Related Issues
Basis in Partnership

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as contributions upon dissolution, resulted in cancellation of indebtedness income. Background to Hohl et al. v. Commissioner Hohl, Blake, and Bowles were partners in a partnership

Read More »
Scott St. Amand January 13, 2021
Income Tax Issues
Expectation of Repayment

Estate of Bolles v. Commissioner
T.C. Memo. 2020-71

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Bolles v. Commissioner (T.C. Memo. 2020-71). The sole issue before the court in Estate of Bolles v. Commissioner was whether the transfers from the decedent, Mary Bolles, to her son Peter, which transfers aggregated over $1m, should be treated as loans or gifts. According to the Tax Court, “Each side sees the answer as totally one way. We disagree

Read More »
Scott St. Amand June 1, 2020
Income Tax Issues
Conditional Repayment

Novoselsky v. Commissioner
T.C. Memo. 2020-68

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Novoselsky v. Commissioner (T.C. Memo. 2020-68). The issues before the court in Novoselsky v. Commissioner were (1) whether (1) the litigation advance support payments were loans or gross income, and whether petitioners were liable for accuracy-related penalties. Background Facts to Novoselsky v. Commissioner During 2009 and 2011, the petitioner-husband (PH) practiced law with a focus on class action litigation. In

Read More »
Scott St. Amand May 28, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Kelly v. Commissioner
T.C. Memo. 2021-76

On June 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelly v. Commissioner (T.C. Memo. 2021-76). The primary issues presented in Kelly v. Commissioner were whether transfers from a company to the petitioner were loans, and if so, whether the petitioner received taxable distributions or

Read More »
Scott St. Amand July 12, 2021

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as

Read More »
Scott St. Amand January 13, 2021

Estate of Bolles v. Commissioner
T.C. Memo. 2020-71

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Bolles v. Commissioner (T.C. Memo. 2020-71). The sole issue before the court in Estate of Bolles v. Commissioner was whether the transfers from the decedent, Mary Bolles, to her son Peter, which transfers aggregated

Read More »
Scott St. Amand June 1, 2020

Novoselsky v. Commissioner
T.C. Memo. 2020-68

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Novoselsky v. Commissioner (T.C. Memo. 2020-68). The issues before the court in Novoselsky v. Commissioner were (1) whether (1) the litigation advance support payments were loans or gross income, and whether petitioners were liable for

Read More »
Scott St. Amand May 28, 2020