Penalties Under the Code
Accuracy Related Penalty

Babu v. Commissioner
T.C. Memo. 2020-121

On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Babu v. Commissioner (T.C. Memo. 2020-121). The sole issue before the court in Babu v. Commissioner was whether the petitioner was liable for the substantial understatement accuracy-related penalty under IRC § 6662(a), IRC § 6662(b)(2), IRC § 6662(d)(2). Background to Babu v. Commissioner After earning a B.A. degree in finance, Mr. Babu attended law school at the University of Baltimore,

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Scott St. Amand August 17, 2020
Business Related Issues
Badges of Fraud

Collins v. Commissioner
T.C. Memo. 2020-50

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins v. Commissioner were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2) whether the petitioners are liable for additions to tax for failing to timely file their returns; and whether petitioner-husband is liable for the civil fraud

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Scott St. Amand April 23, 2020
Bad Advice

Campbell v. Commissioner
T.C. Memo. 2020-41

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Campbell v. Commissioner (T.C. Memo. 2020-41). The primary issue before the court in Campbell v. Commissioner was whether petitioners are entitled to a charitable contribution deduction with respect to donation, which hinges on the issues of whether the taxpayer submitted appropriate substantiation for the contribution and/or reasonably relied on the advice of a CPA that the charitable deduction was appropriate.

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Scott St. Amand April 7, 2020
Income Tax Issues
Bad Advice

Cuthbertson v. Commissioner
T.C. Memo. 2020-9

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Cuthbertson v. Commissioner (T.C. Memo. 2020-9). The issues presented in Cuthbertson v. Commissioner were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2) whether the installment method of accounting was an appropriate method of accounting to report the transfer of property between two companies, both wholly owned by

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Scott St. Amand January 14, 2020
Income Tax Issues
Accuracy Related Penalty

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

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Scott St. Amand January 13, 2020
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Babu v. Commissioner
T.C. Memo. 2020-121

On August 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Babu v. Commissioner (T.C. Memo. 2020-121). The sole issue before the court in Babu v. Commissioner was whether the petitioner was liable for the substantial understatement accuracy-related penalty under IRC § 6662(a), IRC § 6662(b)(2),

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Scott St. Amand August 17, 2020

Collins v. Commissioner
T.C. Memo. 2020-50

On April 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Collins v. Commissioner (T.C. Memo. 2020-50). The issues before the court in Collins v. Commissioner were (1) whether petitioners were entitled to numerous categories of deductions and whether they provided substantiation to prove entitlement; (2)

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Scott St. Amand April 23, 2020

Campbell v. Commissioner
T.C. Memo. 2020-41

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Campbell v. Commissioner (T.C. Memo. 2020-41). The primary issue before the court in Campbell v. Commissioner was whether petitioners are entitled to a charitable contribution deduction with respect to donation, which hinges on the issues

Read More »
Scott St. Amand April 7, 2020

Cuthbertson v. Commissioner
T.C. Memo. 2020-9

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Cuthbertson v. Commissioner (T.C. Memo. 2020-9). The issues presented in Cuthbertson v. Commissioner were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2)

Read More »
Scott St. Amand January 14, 2020

Rivera v. Commissioner
T.C. Memo. 2020-7

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to

Read More »
Scott St. Amand January 13, 2020