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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Scott St. Amand April 24, 2022
Procedural Issues
Higbee v. Commissioner

On Penalties and Burdens

A burden is a burden, right?  A thirty-three-year-old man-child, living in his mother’s basement, with a Cheeto-stained, self-described “ironical” mustache, then yes.  That’s a burden, no matter how you slice it.  No need to prove it or to produce evidence to support it.  He’s a bum and a burden.  Shave the flavor saver, and get a damn job, hippie. Proof and production, though.  Six of one, half a dozen of another?  Not when it comes

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Scott St. Amand August 30, 2021
Business Related Issues
Accuracy Related Penalty

Plentywood Drug Inc. v. Commissioner
T.C. Memo. 2021-45

On April 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Plentywood Drug Inc. v. Commissioner (T.C. Memo. 2021-45). The primary issues presented in Plentywood Drug, Inc. were whether the petitioner’s owners received “fair rent” or constructive dividends for the rental of the petitioner’s drug store, and whether the petitioner (a corporation) satisfied its burden to show that the IRS failed to receive prior supervisory approval for the accuracy-related penalties at

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Scott St. Amand April 26, 2021
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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 »
Scott St. Amand April 24, 2022

On Penalties and Burdens

A burden is a burden, right?  A thirty-three-year-old man-child, living in his mother’s basement, with a Cheeto-stained, self-described “ironical” mustache, then yes.  That’s a burden, no matter how you slice it.  No need to prove it or to produce evidence to support it.  He’s a bum and a burden.  Shave

Read More »
Scott St. Amand August 30, 2021

Plentywood Drug Inc. v. Commissioner
T.C. Memo. 2021-45

On April 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Plentywood Drug Inc. v. Commissioner (T.C. Memo. 2021-45). The primary issues presented in Plentywood Drug, Inc. were whether the petitioner’s owners received “fair rent” or constructive dividends for the rental of the petitioner’s drug store,

Read More »
Scott St. Amand April 26, 2021