Income Tax Issues
Books and Records

Harwood v. Commissioner (T.C. Memo. 2022-8)

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years at issue, Mr. Harwood worked as a steamfitter and brazier on construction projects in Washington and Oregon. Mr. Harwood joined Plumber and Steamfitters Local 598

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Income Tax Issues
Books and Records

Elbasha v. Commissioner (T.C. Memo. 2022-1)

On January 12, 2022, the Tax Court issued a Memorandum Opinion in the case of Elbasha v. Commissioner (T.C. Memo. 2022-1). The primary issues presented in Elbasha were the petitioner’s filing status and whether and to what extent the petitioner can deduct Schedule C expenses. Background The petitioner, an emergency room doctor, was born in Sudan, and he had family there during 2008 and 2009—the years at issue. The petitioner’s Sudanese family included his wife,

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Income Tax Issues
Books and Records

Safaryan v. Commissioner (T.C. Memo. 2021-138)

On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held: Not so much. Background to Safaryan v. Commissioner In 2012 or 2013 the petitioner-husband purchased 10 acres of property in Newberry Springs, California. The property

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Procedural Issues
Bankruptcy

Wathen v. Commissioner (T.C. Memo. 2021-100)

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable for the failure to file penalty for 2010 and 2011, and whether the petitioner is liable for the substantial understatement accuracy-related penalty. Background to Wathen

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Income Tax Issues
Accuracy Related Penalty

Vennes v. Commissioner (T.C. Memo. 2021-93)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty pursuant to IRC § 6662(a). A Checkered Past In 1990, the petitioner completed a prison sentence for money laundering, narcotics, and firearms offenses. After his

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Income Tax Issues
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

Taxation of Cryptocurrency, a Primer – Taxing, Briefly

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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Harwood v. Commissioner (T.C. Memo. 2022-8)

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years

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Elbasha v. Commissioner (T.C. Memo. 2022-1)

On January 12, 2022, the Tax Court issued a Memorandum Opinion in the case of Elbasha v. Commissioner (T.C. Memo. 2022-1). The primary issues presented in Elbasha were the petitioner’s filing status and whether and to what extent the petitioner can deduct Schedule C expenses. Background The petitioner, an emergency

Read More »

Safaryan v. Commissioner (T.C. Memo. 2021-138)

On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held:

Read More »

Wathen v. Commissioner (T.C. Memo. 2021-100)

On August 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Wathen v. Commissioner (T.C. Memo. 2021-100). The primary issues presented in Wathen were whether the petitioner failed to report income, whether the petitioner is entitled to deductions on Schedule C, whether the petitioner is liable

Read More »

Vennes v. Commissioner (T.C. Memo. 2021-93)

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty

Read More »

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

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