Books and Records

Keels v. Commissioner (T.C. Memo. 2020-25)

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised the application of IRC § 409A as a new basis for disallowance of the petitioner’s deductions (which had not been raised in the notice of deficiency), consequently

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Charitable Contributions

Oakhill Woods LLC v. Commissioner (T.C. Memo. 2020-24)

On February 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Oakhill Woods, LLC v. Commissioner (T.C. Memo. 2020-24). The issues presented in Oakhill Woods, LLC were whether the petitioner satisfied for this donation the substantiation requirements of Treas. Reg. § 1.170A-13(c), and if it did not, whether Treas. Reg. § 1.170A-13(c) is, itself, invalid.

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Books and Records

Near v. Commissioner (T.C. Memo. 2020-10)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when the employee had a right to seek reimbursement from his employer.

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Accuracy Related Penalty

Rivera v. Commissioner (T.C. Memo. 2020-7)

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions claimed on the partnership returns, and (3) the petitioners are liable for IRC § 6662(a) accuracy-related penalties.

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Abuse of Discretion

Hommel v. Commissioner (T.C. Memo. 2020-4)

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue, however, was how close Judge Holmes could get to calling the petitioner a #^&%$ idiot without actually doing so.

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Charitable Contributions

Loube v. Commissioner (T.C. Memo. 2020-3)

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Loube v. Commissioner (T.C. Memo. 2020-3). The issues presented in Loube were whether the petitioners had complied with § 155 of the Deficit Reduction Act of 1984 (DEFRA) with respect to the appraisal that they obtained regarding charitable deductions claimed on their return; and if not, whether the petitioners were in substantial compliance with DEFRA.

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Keels v. Commissioner (T.C. Memo. 2020-25)

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised the application

Read More »

Oakhill Woods LLC v. Commissioner (T.C. Memo. 2020-24)

On February 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Oakhill Woods, LLC v. Commissioner (T.C. Memo. 2020-24). The issues presented in Oakhill Woods, LLC were whether the petitioner satisfied for this donation the substantiation requirements of Treas. Reg. § 1.170A-13(c), and if it did

Read More »

Near v. Commissioner (T.C. Memo. 2020-10)

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when

Read More »

Rivera v. Commissioner (T.C. Memo. 2020-7)

On January 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Rivera v. Commissioner (T.C. Memo. 2020-7). The issues presented in Rivera were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to certain deductions

Read More »

Hommel v. Commissioner (T.C. Memo. 2020-4)

On January 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Hommel v. Commissioner (T.C. Memo. 2020-4). The issue presented in Hommel was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The real issue,

Read More »

Loube v. Commissioner (T.C. Memo. 2020-3)

On January 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Loube v. Commissioner (T.C. Memo. 2020-3). The issues presented in Loube were whether the petitioners had complied with § 155 of the Deficit Reduction Act of 1984 (DEFRA) with respect to the appraisal that they

Read More »