Amortization under IRC § 197

Complex Media, Inc. v. Commissioner (T.C. Memo. 2021-14)

On February 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Complex Media, Inc. v. Commissioner (T.C. Memo. 2021-14). The primary issue presented in Complex Media was whether a taxpayer was eligible to disavow the form of its transactions (an asset transfer) when the alternative form achieves a tax benefit “not inconsistent” with the taxpayer’s initial tax planning and structuring of the transactions. Background The petitioner acquired the assets of a

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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 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 S of

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Substance Over Form Argument

Watts v. Commissioner (T.C. Memo. 2020-144)

On October 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Watts v. Commissioner (T.C. Memo. 2020-143). The issues before the court in Watts were (1) whether the “Danielson rule” applies to limit the invocation of the substance-over-form doctrine by taxpayers in certain cases; and (2) if so, whether petitioners proved that the Watts family had a separate, enforceable oral agreement with Wellspring that predated the purchase by Sun Capital, and,

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Economic Substance Doctrine

Daichman v. Commissioner (T.C. Memo. 2020-126)

On August 31, 2020, the Tax Court issued a Memorandum Opinion in the case of Daichman v. Commissioner (T.C. Memo. 2020-126). The primary issue before the court in Daichman was whether the petitioners are entitled to a short-term capital loss deduction of $2.1 million in connection with the dissolution of their S corporation or whether their tax transactions lacked economic substance.

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Bad Advice

Cuthbertson v. Commissioner (T.C. Memo. 2020-9)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Cuthbertson v. Commissioner (T.C. Memo. 2020-9). The issues presented in Culbertson were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2) whether the installment method of accounting was an appropriate method of accounting to report the transfer of property between two companies, both wholly owned by the petitioners.

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Aunt Ethel

Deducting Charitable Contributions from a Trust that Does not Permit Charitable Contributions

Uncle Bill comes to your office in a bit of a tizzy with two beers in one hand and three notices from the IRS in the other.  Although you are not unaccustomed to his unannounced visits, they are nevertheless jarring at 7:15 on a Tuesday morning.  Aunt Ethel explained that Bill has become more nocturnal in his advancing age, and, as such, he is not, technically, day drinking – at least not in his personal

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Complex Media, Inc. v. Commissioner (T.C. Memo. 2021-14)

On February 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Complex Media, Inc. v. Commissioner (T.C. Memo. 2021-14). The primary issue presented in Complex Media was whether a taxpayer was eligible to disavow the form of its transactions (an asset transfer) when the alternative form

Read More »

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 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

Read More »

Watts v. Commissioner (T.C. Memo. 2020-144)

On October 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Watts v. Commissioner (T.C. Memo. 2020-143). The issues before the court in Watts were (1) whether the “Danielson rule” applies to limit the invocation of the substance-over-form doctrine by taxpayers in certain cases; and (2)

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Daichman v. Commissioner (T.C. Memo. 2020-126)

On August 31, 2020, the Tax Court issued a Memorandum Opinion in the case of Daichman v. Commissioner (T.C. Memo. 2020-126). The primary issue before the court in Daichman was whether the petitioners are entitled to a short-term capital loss deduction of $2.1 million in connection with the dissolution of

Read More »

Cuthbertson v. Commissioner (T.C. Memo. 2020-9)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Cuthbertson v. Commissioner (T.C. Memo. 2020-9). The issues presented in Culbertson were (1) whether the petitioners were entitled to loss deductions arising from the sale or abandonment of golf course improvements, and (2) whether the

Read More »