Business Related Issues
C Corporations

Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v. Commissioner I find the petitioner suspect.  First off, it is an Iowa C corporation, but it is not involved with the production or processing of

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Scott St. Amand January 21, 2021
Business Related Issues
Blame Kentucky

Deckard v. Commissioner
155 T.C. No. 8

On September 17, 2020, the Tax Court issued its opinion in Deckard v. Commissioner (155 T.C. No. 8). The primary issue presented in Deckard v. Commissioner was whether as the officer and director of a Kentucky non-stock, non-profit corporation (as constrained by Kentucky law and the company’s articles of incorporation), the taxpayer had an ownership interest in the company equivalent to that of a shareholder for purposes of applying the passthrough loss provisions of subchapter

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Scott St. Amand September 17, 2020
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Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v.

Read More »
Scott St. Amand January 21, 2021

Deckard v. Commissioner
155 T.C. No. 8

On September 17, 2020, the Tax Court issued its opinion in Deckard v. Commissioner (155 T.C. No. 8). The primary issue presented in Deckard v. Commissioner was whether as the officer and director of a Kentucky non-stock, non-profit corporation (as constrained by Kentucky law and the company’s articles of incorporation),

Read More »
Scott St. Amand September 17, 2020