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

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to IRC § 165. Background As of 2016, the petitioner was illiterate—whether because of an illness or because he didn’t ascribe much to them book learnings,

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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: Bamboozled, Hoodwinked, Swindled, and

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Business Related Issues
Accuracy Related Penalty

Filler v. Commissioner (T.C. Memo. 2021-6)

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Filler v. Commissioner (T.C. Memo. 2021-6). The issues presented in Filler were whether the petitioner (1) properly reported $100,000 in income received as capital gain rather than ordinary income; (2) is liable for self-employment tax; (3) is entitled to deduct a net operating loss carryover originating in tax year 2012; and (4) is liable for penalty under IRC § 6662(a).

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Income Tax Issues
IRC § 165

Giambrone v. Commissioner (T.C. Memo. 2020-145)

On October 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Giambrone v. Commissioner (T.C. Memo. 2020-145). The primary issue before the court in Giambrone is whether the IRS improperly disallowed a theft loss deduction that the petitioners claimed on their respective 2012 returns.

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Income Tax Issues
Accuracy Related Penalty

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for the IRC

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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 »

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to

Read More »

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 »

Filler v. Commissioner (T.C. Memo. 2021-6)

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Filler v. Commissioner (T.C. Memo. 2021-6). The issues presented in Filler were whether the petitioner (1) properly reported $100,000 in income received as capital gain rather than ordinary income; (2) is liable for self-employment tax;

Read More »

Giambrone v. Commissioner (T.C. Memo. 2020-145)

On October 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Giambrone v. Commissioner (T.C. Memo. 2020-145). The primary issue before the court in Giambrone is whether the IRS improperly disallowed a theft loss deduction that the petitioners claimed on their respective 2012 returns.

Read More »

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether

Read More »