Procedural Issues
Deposit of Partial Payment of Liabilities

Hill v. Commissioner
T.C. Memo. 2021-121

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill v. Commissioner was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for 2011, which remittance was designated as a “deposit” was a “deposit” or a “payment” for purposes of determining whether interest was due to the petitioner.

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Scott St. Amand November 10, 2021
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

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Scott St. Amand March 11, 2020
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Hill v. Commissioner
T.C. Memo. 2021-121

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill v. Commissioner was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for

Read More »
Scott St. Amand November 10, 2021

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