Income Tax Issues
Accuracy Related Penalty

Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay advance premium tax credit (APTC) payments of the PTC. Held: Yup and yeppers. Background to Knox v. Commissioner The petitioners were (and perhaps still are)

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Scott St. Amand March 30, 2022
Income Tax Issues
Constitutional Due Process Argument

Kelley v. Commissioner
T.C. Memo. 2021-2

On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelley v. Commissioner (T.C. Memo. 2021-2). The issue presented in Kelley v. Commissioner was whether the provisions of IRC § 86(c) violated his Constitutional due process rights…and “various other constitutional arguments” that the Tax Court did not deign to address. Preface to Kelley v. Commissioner Anyone who has read Briefly Taxing for any length of time—you know who you are—knows

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Scott St. Amand January 11, 2021
Income Tax Issues
Jurisdiction of Tax Court

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount he received as Social Security Disability Insurance (SSDI) benefits. Background to Staples v. Commissioner The petitioner worked for the USPTO until disability forced him to

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Scott St. Amand March 11, 2020
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Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay

Read More »
Scott St. Amand March 30, 2022

Kelley v. Commissioner
T.C. Memo. 2021-2

On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelley v. Commissioner (T.C. Memo. 2021-2). The issue presented in Kelley v. Commissioner was whether the provisions of IRC § 86(c) violated his Constitutional due process rights…and “various other constitutional arguments” that the Tax Court

Read More »
Scott St. Amand January 11, 2021

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount

Read More »
Scott St. Amand March 11, 2020