Income Tax Issues
Capital Expenditures

Deducting Legal and Professional Fees

Income tax deductions are rather like hard truths. A client may not want to hear that an item is not deductible, but you know in your heart of hearts that you cannot, in good conscience, advise them otherwise. No doctor relishes the prospect of telling a patient that he is terminal. Often met with a similar grief-stricken reaction, explaining to a client that the “big ticket” deduction that they wanted to claim (or in my

Read More »
Scott St. Amand April 29, 2021
Income Tax Issues
Abandonment

Reckless (albeit Tax Conscious) Abandonment under IRC § 165

Uncle Bill is somewhat of a hoarder.  In truth, the only thing that he has ever abandoned was his first wife…in a Waffle House at 2:15 AM on the outskirts of Norman, Oklahoma. In Bill’s defense, she had tried to stab him. In her defense, he probably deserved it. When Bill comes to you to chat about IRC § 165 losses—so-called “abandonment” losses—you know he has some hairbrained scheme in his head to stick it

Read More »
Scott St. Amand April 29, 2021
Income Tax Issues
Accuracy Related Penalty

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for

Read More »
Scott St. Amand April 9, 2020
Income Tax Issues
Jurisdiction of Tax Court

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount he received as Social Security Disability Insurance (SSDI) benefits. Background to Staples v. Commissioner The petitioner worked for the USPTO until disability forced him to

Read More »
Scott St. Amand March 11, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Deducting Legal and Professional Fees

Income tax deductions are rather like hard truths. A client may not want to hear that an item is not deductible, but you know in your heart of hearts that you cannot, in good conscience, advise them otherwise. No doctor relishes the prospect of telling a patient that he is

Read More »
Scott St. Amand April 29, 2021

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue;

Read More »
Scott St. Amand April 9, 2020

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount

Read More »
Scott St. Amand March 11, 2020