Income Tax Issues
Books and Records

Harwood v. Commissioner
T.C. Memo. 2022-8

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years at issue, Mr. Harwood worked as a steamfitter and brazier on construction projects in Washington and Oregon. Mr. Harwood joined Plumber and Steamfitters Local 598

Read More »
Scott St. Amand May 13, 2022
Income Tax Issues
“At Risk” Rules

Personal Liability under the At Risk Rules

So, you have a business loss.  Join the club.  The real question is whether you have personal liability under the at risk rules of IRC § 465. Personal Liability under the At Risk Rules of IRC § 465 For certain taxpayers (including individuals and certain closely held corporations), who are engaged in certain activities (including each activity engaged in by the taxpayer in carrying on a trade or business or for the production of income),

Read More »
Scott St. Amand April 29, 2021
Business Related Issues
“At Risk” Rules

Bordelon v. Commissioner
T.C. Memo. 2020-26

On February 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Bordelon v. Commissioner (T.C. Memo. 2020-26). The issues presented in Bordelon v. Commissioner were (1) whether the petitioner-husband’s personal guarantee of a loan established sufficient amounts “at risk” under IRC § 465 to permit deduction of a loss related to a wholly-owned LLC in 2008; and (2) whether petitioner-husband’s personal guarantee of a second loan increased his basis in a

Read More »
Scott St. Amand February 20, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular tagged posts:

Harwood v. Commissioner
T.C. Memo. 2022-8

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years

Read More »
Scott St. Amand May 13, 2022

Personal Liability under the At Risk Rules

So, you have a business loss.  Join the club.  The real question is whether you have personal liability under the at risk rules of IRC § 465. Personal Liability under the At Risk Rules of IRC § 465 For certain taxpayers (including individuals and certain closely held corporations), who are

Read More »
Scott St. Amand April 29, 2021

Bordelon v. Commissioner
T.C. Memo. 2020-26

On February 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Bordelon v. Commissioner (T.C. Memo. 2020-26). The issues presented in Bordelon v. Commissioner were (1) whether the petitioner-husband’s personal guarantee of a loan established sufficient amounts “at risk” under IRC § 465 to permit deduction

Read More »
Scott St. Amand February 20, 2020