Income Tax Issues
Deductions

Sharma v. Commissioner
T.C. Memo. 2020-147

On October 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Sharma v. Commissioner (T.C. Memo. 2020-147). The primary issue before the court in Sharma v. Commissioner was what portion of the petitioners’ loss deduction from rental real estate activities claimed on Schedule E (Supplemental Income and Loss), is disallowed under the IRC § 469(a) and (i) limitations on the deductibility of passive activity losses.

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Scott St. Amand October 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
Deductibility of Expenses

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses in General as explained by Christensen v. Commissioner Because deductions are a “matter of legislative grace,” taxpayers bear the burden of establishing their entitlement thereto.

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Scott St. Amand January 15, 2020
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Sharma v. Commissioner
T.C. Memo. 2020-147

On October 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Sharma v. Commissioner (T.C. Memo. 2020-147). The primary issue before the court in Sharma v. Commissioner was what portion of the petitioners’ loss deduction from rental real estate activities claimed on Schedule E (Supplemental Income

Read More »
Scott St. Amand October 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

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses

Read More »
Scott St. Amand January 15, 2020