Income Tax Issues
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 v. Commissioner 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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Scott St. Amand January 13, 2020
Business Related Issues
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 v. Commissioner 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. Personal Note in Hommel

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Scott St. Amand January 8, 2020
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 v. Commissioner 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. Charitable Contributions, Generally

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Scott St. Amand January 6, 2020
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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 v. Commissioner were whether (1) the petitioners’ partnership received and failed to report gross receipts on Forms 1065, (2) the partnership is entitled to

Read More »
Scott St. Amand January 13, 2020

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 v. Commissioner was whether a petitioner, who presented no evidence to the contrary, could challenge a bank deposits analysis for abuse of discretion.  The

Read More »
Scott St. Amand January 8, 2020

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 v. Commissioner were whether the petitioners had complied with § 155 of the Deficit Reduction Act of 1984 (DEFRA) with respect to the appraisal

Read More »
Scott St. Amand January 6, 2020