Procedural Issues
31 C.F.R. § 10.0

FAB Holdings LLC v. Commissioner
T.C. Memo. 2021-135

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of FAB Holdings LLC v. Commissioner (T.C. Memo. 2021-135). The primary issue presented in FAB Holdings was whether the statutory notices of deficiency (SNODs) were timely sent based upon a cockamamy argument that the petitioners’ CPA was a “promoter” because the petitioners paid for his services. Held: The Tax Court was “not persuaded” by such argument. Background to FAB Holdings LLC

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Scott St. Amand April 21, 2022
Business Related Issues
Burden of Proof

Berry v. Commissioner
T.C. Memo. 2021-42

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry v. Commissioner were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether the petitioners are entitled to certain claimed deductions, and whether the petitioners are liable for accuracy-related penalties under IRC § 6662. Background to Berry v.

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Scott St. Amand April 7, 2021
Penalties Under the Code
Accuracy Related Penalty

Walton v. Commissioner
T.C. Memo. 2021-40

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background to Walton v. Commissioner The petitioner was a New Yorker,[1] who failed to report $170,000 in nonemployee compensation in 2015. Strike one and two. The petitioner was terminated from her

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Scott St. Amand March 30, 2021
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FAB Holdings LLC v. Commissioner
T.C. Memo. 2021-135

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of FAB Holdings LLC v. Commissioner (T.C. Memo. 2021-135). The primary issue presented in FAB Holdings was whether the statutory notices of deficiency (SNODs) were timely sent based upon a cockamamy argument that the petitioners’ CPA

Read More »
Scott St. Amand April 21, 2022

Berry v. Commissioner
T.C. Memo. 2021-42

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry v. Commissioner were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether

Read More »
Scott St. Amand April 7, 2021

Walton v. Commissioner
T.C. Memo. 2021-40

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background to Walton v. Commissioner The

Read More »
Scott St. Amand March 30, 2021