Deductions

Geiman v. Commissioner (T.C. Memo. 2021-80)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background The petitioner is a union electrician who spent most of 2013 on jobs in various parts of Wyoming and Colorado. He claimed on his 2013 Federal

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Taxing, Briefly
Bitcoin

Taxing, Briefly: Taxing Cryptocurrency, a Primer

In the 36 years I have been on this mortal plane, I can’t remember ever thinking I was, as the kids say (or said in the 1990s) hip.  In full candor, the only time your fearless editor uses the word is when I explain to my sprightly wife that my hip hurts because it’s going to rain, and I’ve been sitting on the lawn chair on my porch too long, yelling at the whippersnappers to

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Books and Records

Adler v. Commissioner (T.C. Memo. 2021-56)

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Adler v. Commissioner (T.C. Memo. 2021-56). The primary issue presented in Adler was whether the petitioner was entitled to deduct business expenses for 2016 and 2017 (the years in issue). In Short The petitioner was a consultant for an entertainment company in Los Angeles.  He incurred business-related expenses, including travel expenses, and he reported these expenses on his Schedule C

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Accuracy Related Penalty

Berry v. Commissioner (T.C. Memo. 2021-52)

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is entitled to deduct racecar expenses, and whether or not the petitioners substantiated COGS or a depreciation deduction under IRC § 167(a). Background You may remember

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Books and Records

Chancellor v. Commissioner (T.C. Memo. 2021-50)

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local tax. Brief Background Ms. Viola Chancellor, of Nevada, is a notary and a paralegal.  In 2015, she received $400 from her duties as such.  She reported a

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Bank Deposits Analysis

Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47)

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context This is an unreported income case, and the opinion is all of six pages long.  One has expectations of a couple thousand dollars-worth of unreported income.  But not

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Accuracy Related Penalty

Baum v. Commissioner (T.C. Memo. 2021-46)

On April 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Baum v. Commissioner (T.C. Memo. 2021-46). The primary issues presented in Baum were whether the petitioners were entitled to deductions for expenses as reported on Schedules C (Profit or Loss from Business) for the years in issue and whether the petitioners were entitled to a theft loss deduction pursuant to IRC § 165 for 2015. Background: Bamboozled, Hoodwinked, Swindled, and

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Geiman v. Commissioner (T.C. Memo. 2021-80)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background The

Read More »

Taxing, Briefly: Taxing Cryptocurrency, a Primer

In the 36 years I have been on this mortal plane, I can’t remember ever thinking I was, as the kids say (or said in the 1990s) hip.  In full candor, the only time your fearless editor uses the word is when I explain to my sprightly wife that my

Read More »

Adler v. Commissioner (T.C. Memo. 2021-56)

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Adler v. Commissioner (T.C. Memo. 2021-56). The primary issue presented in Adler was whether the petitioner was entitled to deduct business expenses for 2016 and 2017 (the years in issue). In Short The petitioner was

Read More »

Berry v. Commissioner (T.C. Memo. 2021-52)

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is

Read More »

Chancellor v. Commissioner (T.C. Memo. 2021-50)

On May 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Chancellor v. Commissioner (T.C. Memo. 2021-50). The primary issue presented in Chancellor was whether the IRS erred in disallowing deductions the petitioner claimed for certain business expenses, charitable contributions, and state and local tax. Brief

Read More »

Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47)

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context This is an

Read More »

Baum v. Commissioner (T.C. Memo. 2021-46)

On April 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Baum v. Commissioner (T.C. Memo. 2021-46). The primary issues presented in Baum were whether the petitioners were entitled to deductions for expenses as reported on Schedules C (Profit or Loss from Business) for the years

Read More »