Income Tax Issues
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 to Baum v. Commissioner:

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Scott St. Amand April 27, 2021
Income Tax Issues
Accuracy Related Penalty

Purple Heart Patient Center Inc. v. Commissioner
T.C. Memo. 2021-38

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Purple Heart Patient Center Inc. v. Commissioner (T.C. Memo. 2021-38). The primary issues presented in Purple Heart Patient Center Inc. v. Commissioner were whether the petitioner (1) was entitled to offset its gross receipts with any cost of goods sold (COGS), (2) underreported its gross income, and (3) is liable for the accuracy-related penalty pursuant to IRC § 6662(a). Background to Purple

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Scott St. Amand March 29, 2021
Income Tax Issues
Bank Deposits Analysis

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for filing (very) late and for being (very) negligent and for (very) substantially understating their liabilities. Background to NOLs in Martin v. Commissioner The

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Scott St. Amand March 14, 2021
Business Related Issues
Books and Records

Lucero v. Commissioner
T.C. Memo. 2020-136

On September 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Lucero v. Commissioner (T.C. Memo. 2020-136). The issue before the court in Lucero v. Commissioner was whether the petitioners’ real estate loss deductions were disallowed by IRC § 469 and/or IRC § 280A. Background to Lucero v. Commissioner The petitioner-husband owned a short-term rental property in The Sea Ranch, California. To be clear, the property was not in Sea Ranch,

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Scott St. Amand September 29, 2020
Business Related Issues
Bad Debt Losses

Franklin v. Commissioner
T.C. Memo. 2020-127

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin v. Commissioner were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled to deduct certain business losses. Creating Substantiation in Franklin v. Commissioner The petitioner was in the real estate investment consulting business, which appears to be

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Scott St. Amand September 3, 2020
Income Tax Issues
IRC § 162

Brashear v. Commissioner
T.C. Memo. 2020-122

On August 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Brashear v. Commissioner (T.C. Memo. 2020-122). The primary issue before the court in Brashear was whether the petitioners were entitled to various deductions on Schedule C (Profits and Loss from Business). Business-Related Deductions 101 in Brashear v. Commissioner The taxpayer’s burden of proof regarding entitlement to deductions requires the taxpayer to substantiate all expenses underlying the deductions claimed by keeping

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Scott St. Amand August 19, 2020
Income Tax Issues
Books and Records

Sham v. Commissioner
T.C. Memo. 2020-119

On August 12, 2020, the Tax Court issued a Memorandum Opinion in the case of Sham v. Commissioner (T.C. Memo. 2020-119). The primary issues before the court in Sham v. Commissioner were whether the petitioner had (or could) substantiate significant itemized deductions, business deductions, and other “miscellaneous” deductions, and (2) whether the petitioner had failed to report (or maintain records of) her gross receipts. Introductory Note to Sham v. Commissioner My dad ran political campaigns

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Scott St. Amand August 12, 2020
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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 »
Scott St. Amand April 27, 2021

Purple Heart Patient Center Inc. v. Commissioner
T.C. Memo. 2021-38

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Purple Heart Patient Center Inc. v. Commissioner (T.C. Memo. 2021-38). The primary issues presented in Purple Heart Patient Center Inc. v. Commissioner were whether the petitioner (1) was entitled to offset its gross receipts with any

Read More »
Scott St. Amand March 29, 2021

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for

Read More »
Scott St. Amand March 14, 2021

Lucero v. Commissioner
T.C. Memo. 2020-136

On September 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Lucero v. Commissioner (T.C. Memo. 2020-136). The issue before the court in Lucero v. Commissioner was whether the petitioners’ real estate loss deductions were disallowed by IRC § 469 and/or IRC § 280A. Background to

Read More »
Scott St. Amand September 29, 2020

Franklin v. Commissioner
T.C. Memo. 2020-127

On September 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Franklin v. Commissioner (T.C. Memo. 2020-127). The primary issues before the court in Franklin v. Commissioner were whether the petitioner was entitled to meal, entertainment, and travel expense deductions and whether the petitioner was entitled

Read More »
Scott St. Amand September 3, 2020

Brashear v. Commissioner
T.C. Memo. 2020-122

On August 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Brashear v. Commissioner (T.C. Memo. 2020-122). The primary issue before the court in Brashear was whether the petitioners were entitled to various deductions on Schedule C (Profits and Loss from Business). Business-Related Deductions 101 in

Read More »
Scott St. Amand August 19, 2020

Sham v. Commissioner
T.C. Memo. 2020-119

On August 12, 2020, the Tax Court issued a Memorandum Opinion in the case of Sham v. Commissioner (T.C. Memo. 2020-119). The primary issues before the court in Sham v. Commissioner were whether the petitioner had (or could) substantiate significant itemized deductions, business deductions, and other “miscellaneous” deductions, and (2)

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Scott St. Amand August 12, 2020