Debt Financing

Tribune Media Company v. Commissioner (T.C. Memo. 2021-122)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Tribune Media Company v. Commissioner (T.C. Memo. 2021-122). The primary issue presented in Tribune Media Company was whether the Ricketts family (a partner of the petitioner in “Chicago Baseball Holdings, LLC”) entered into a “bona fide debt” for tax purposes. (You may remember these parties from the January 2020 decision of Chicago Baseball Holdings v. Commissioner, T.C. Memo. 2020-2). Held:

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Income Tax Issues
Abuse of Discretion

Dodd v. Commissioner (T.C. Memo. 2021-118)

On October 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Dodd v. Commissioner (T.C. Memo. 2021-118). The primary issue presented in Dodd were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background During 2013, the petitioner in Dodd v. Commissioner was employed as the office manager of a law firm in Washington, D.C. During 2013, and continuing at

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Applicable Partnership Interest

Effect of the Build Back Better Act on Corporate and Partnership Taxation

On September 15, the House Ways and Means Committee voted to approve sweeping changes to the Internal Revenue Code through the Build Back Better Act, which proposals, if ultimately passed, will have a significant effect on the taxation of corporations and partnerships. We discussed the changes proposed to affect estate and gift taxation in an earlier article. In this article we explore the effect of the Build Back Better Act on corporate and partnership taxation.

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Procedural Issues
Abatement of Interest

Verghese v. Commissioner (T.C. Memo. 2021-70)

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Verghese v. Commissioner (T.C. Memo. 2021-70). The primary issues presented in Verghese were (1) whether, under IRC § 6404(a) the petitioners are entitled to abatement on the basis of principles of fairness, and (2) whether under IRC § 6404(e) the IRS engaged in ministerial or managerial acts that constituted unreasonable delay for which the petitioners’ abatement request should be granted.

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Capital Interest

ES NPA HOLDING LLC v. Commissioner (T.C. Memo. 2021-68)

On June 3, 2021, the Tax Court issued a Memorandum Opinion in the case of ES NPA HOLDING, LLC v. Commissioner (T.C. Memo. 2021-68). The primary issue presented in ES NPA HOLDING, LLC was whether the adjustment to ES NPA’s 2011 ordinary income originates at the level of another limited liability company, IDS, in which the petitioner held an interest, which is to say that the adjustment is a partnership item of IDS and not

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Income Tax Issues
Deductions

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to IRC § 165. Background As of 2016, the petitioner was illiterate—whether because of an illness or because he didn’t ascribe much to them book learnings,

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Bipartisan Budget Act (BBA)

How to Implement the New Centralized Partnership Audit Regime of the BBA – Part Three

This post, entitled “How to Implement the New Centralized Partnership Audit Regime of the BBA,” is the third and final of a series on the new centralized audit regime that came into effect in 2018 under the Bipartisan Budget Act, replacing the old TEFRA procedures with new partnership-level adjustments.  The first article provided an overview of the primary differences between the BBA regime and that of the old TEFRA procedures.  The second article takes a

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Tribune Media Company v. Commissioner (T.C. Memo. 2021-122)

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Tribune Media Company v. Commissioner (T.C. Memo. 2021-122). The primary issue presented in Tribune Media Company was whether the Ricketts family (a partner of the petitioner in “Chicago Baseball Holdings, LLC”) entered into a “bona

Read More »

Dodd v. Commissioner (T.C. Memo. 2021-118)

On October 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Dodd v. Commissioner (T.C. Memo. 2021-118). The primary issue presented in Dodd were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background During

Read More »

Verghese v. Commissioner (T.C. Memo. 2021-70)

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Verghese v. Commissioner (T.C. Memo. 2021-70). The primary issues presented in Verghese were (1) whether, under IRC § 6404(a) the petitioners are entitled to abatement on the basis of principles of fairness, and (2) whether

Read More »

ES NPA HOLDING LLC v. Commissioner (T.C. Memo. 2021-68)

On June 3, 2021, the Tax Court issued a Memorandum Opinion in the case of ES NPA HOLDING, LLC v. Commissioner (T.C. Memo. 2021-68). The primary issue presented in ES NPA HOLDING, LLC was whether the adjustment to ES NPA’s 2011 ordinary income originates at the level of another limited

Read More »

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to

Read More »