Income Tax Issues
Deductions

Torres v. Commissioner
T.C. Memo. 2021-66

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres v. Commissioner were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to IRC § 165. Background to Torres v. Commissioner As of 2016, the petitioner was illiterate—whether because of an illness or because he didn’t ascribe

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Scott St. Amand June 21, 2021
Income Tax Issues
Divorce

Grossman v. Commissioner
T.C. Memo. 2021-65

On May 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Grossman v. Commissioner (T.C. Memo. 2021-65). The primary issue presented in Grossman v. Commissioner was whether state law determines a taxpayer’s marital status at death for purposes of the marital deduction under IRC § 2056(a). The Saga of Semone in Grossman v. Commissioner All Semone Grossman wanted was to find a nice Jewish girl to settle down with. He had survived

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Scott St. Amand June 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
Penalties Under the Code
IRC § 6901

Alta V Limited Partnership v. Commissioner
T.C. Memo. 2020-8

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed deficiency, penalties, and additions to tax with respect to the transferor’s corporate income tax. Transferee Liability Under the Code – IRC § 6901(a) – Alta

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Scott St. Amand January 13, 2020
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Torres v. Commissioner
T.C. Memo. 2021-66

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres v. Commissioner were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction

Read More »
Scott St. Amand June 21, 2021

Grossman v. Commissioner
T.C. Memo. 2021-65

On May 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Grossman v. Commissioner (T.C. Memo. 2021-65). The primary issue presented in Grossman v. Commissioner was whether state law determines a taxpayer’s marital status at death for purposes of the marital deduction under IRC § 2056(a).

Read More »
Scott St. Amand June 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

Alta V Limited Partnership v. Commissioner
T.C. Memo. 2020-8

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Alta V Limited Partnership v. Commissioner (T.C. Memo. 2020-8). The issue presented in Alta V Limited Partnership v. Commissioner was whether the petitioners were liable as transferees for their portion of the unpaid, determined, and assessed

Read More »
Scott St. Amand January 13, 2020