Business Related Issues
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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Scott St. Amand April 20, 2021
Business Related Issues
Bipartisan Budget Act (BBA)

Understanding the New Centralized Partnership Audit Regime – Part One

This is the first of a series of three posts on the new centralized partnership audit regime that came into effect in 2018 under the Bipartisan Budget Act, replacing the old TEFRA procedures with new partnership-level adjustments.  This first article provides an overview of the primary differences between the BBA regime and that of the old TEFRA procedures.  The second article takes a deep dive into the Code and Treasury Regulations, explaining each new provision

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Scott St. Amand April 20, 2021
Business Related Issues
Bipartisan Budget Act (BBA)

The New Centralized Partnership Audit Regime – Part Two

This is the second of a series of three posts on the new centralized partnership 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.  This second article on the new centralized partnership audit regime takes a deep dive into the Code

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Scott St. Amand April 20, 2021
Business Related Issues
Basis in Partnership

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as contributions upon dissolution, resulted in cancellation of indebtedness income. Background to Hohl et al. v. Commissioner Hohl, Blake, and Bowles were partners in a partnership

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Scott St. Amand January 13, 2021
Business Related Issues
Computational Adjustment

Stevens v. Commissioner
T.C. Memo. 2020-118

On August 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Stevens v. Commissioner (T.C. Memo. 2020-118). The primary issue before the court in Stevens v. Commissioner was whether (and to the what extent) the Tax Court can uphold the IRS’s deficiencies in the face of the petitioners’ claimed partnership loss deductions. The decision of this broad issue hinges on three primary sub-issues, which are whether (1) three partnerships were “small

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Scott St. Amand August 6, 2020
Business Related Issues
Alimony

Schroeder v. Commissioner
T.C. Memo. 2020-117

On August 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Schroeder v. Commissioner (T.C. Memo. 2020-117). The primary issue before the court in Schroeder was whether payments that petitioner-husband made to his petitioner-ex-wife and his divorce lawyer had the effect of increasing the basis in an LLC indirectly owned by petitioner-husband. Background to Schroeder v. Commissioner Petitioner-husband (PH) founded the partnership DCA, LLC in 2003. In 2008, PH assigned his

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Scott St. Amand August 5, 2020
Business Related Issues
Burden of Proof

Simpson v. Commissioner
T.C. Memo. 2020-100

On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions were adjusted in the IRS’s amended answer. Background to Simpson v. Commissioner The IRS issued the petitioners a notice of deficiency for tax years 2012,

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Scott St. Amand July 7, 2020
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The New Centralized Partnership Audit Regime – Part Two

This is the second of a series of three posts on the new centralized partnership 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

Read More »
Scott St. Amand April 20, 2021

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as

Read More »
Scott St. Amand January 13, 2021

Stevens v. Commissioner
T.C. Memo. 2020-118

On August 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Stevens v. Commissioner (T.C. Memo. 2020-118). The primary issue before the court in Stevens v. Commissioner was whether (and to the what extent) the Tax Court can uphold the IRS’s deficiencies in the face of

Read More »
Scott St. Amand August 6, 2020

Schroeder v. Commissioner
T.C. Memo. 2020-117

On August 5, 2020, the Tax Court issued a Memorandum Opinion in the case of Schroeder v. Commissioner (T.C. Memo. 2020-117). The primary issue before the court in Schroeder was whether payments that petitioner-husband made to his petitioner-ex-wife and his divorce lawyer had the effect of increasing the basis in

Read More »
Scott St. Amand August 5, 2020

Simpson v. Commissioner
T.C. Memo. 2020-100

On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions

Read More »
Scott St. Amand July 7, 2020