Business Related Issues
Bad Hackers

Hacker v. Commissioner
(T.C. Memo. 2022-16)

On March 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Hacker v. Commissioner (T.C. Memo. 2022-16). The primary issues presented in Hacker were whether the petitioners received imputed wages and constructive dividends from their day care centers and whether the petitioners were liable for the civil fraud penalty under IRC § 6663. A Note on Hacker v. Commissioner You may remember the Hackers from two Tax Court opinions from 2021,

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Scott St. Amand May 25, 2022
Business Related Issues
C Corporations

Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v. Commissioner I find the petitioner suspect.  First off, it is an Iowa C corporation, but it is not involved with the production or processing of

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Scott St. Amand January 21, 2021
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Hacker v. Commissioner
(T.C. Memo. 2022-16)

On March 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Hacker v. Commissioner (T.C. Memo. 2022-16). The primary issues presented in Hacker were whether the petitioners received imputed wages and constructive dividends from their day care centers and whether the petitioners were liable for the

Read More »
Scott St. Amand May 25, 2022

Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v.

Read More »
Scott St. Amand January 21, 2021