Income Tax Issues
Contingent Fees

Holliday v. Commissioner
T.C. Memo. 2021-69

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday v. Commissioner was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background to Holliday v. Commissioner Two lawsuits are central to this case. The first is petitioner’s divorce proceeding, in which she was represented by J. Beverly and his law firm (divorce attorney and malpractice defendants,

Read More »
Scott St. Amand June 21, 2021
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
Business Related Issues
Origin of the Claim Test

NCA Argyle LP v. Commissioner
T.C. Memo. 2020-56

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of NCA Argyle LP v. Commissioner (T.C. Memo. 2020-56). The basic issue before the court in NCA Argyle LP v. Commissioner was whether proceeds received from the settlement of a lawsuit involving punitive damages which proceeds were received in exchange for the plaintiff/taxpayer’s interests in joint ventures (a capital asset) were properly treated as gain on the sale of a capital

Read More »
Scott St. Amand May 13, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Holliday v. Commissioner
T.C. Memo. 2021-69

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday v. Commissioner was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background to Holliday v. Commissioner Two lawsuits are central to

Read More »
Scott St. Amand June 21, 2021

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

NCA Argyle LP v. Commissioner
T.C. Memo. 2020-56

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of NCA Argyle LP v. Commissioner (T.C. Memo. 2020-56). The basic issue before the court in NCA Argyle LP v. Commissioner was whether proceeds received from the settlement of a lawsuit involving punitive damages which proceeds

Read More »
Scott St. Amand May 13, 2020