Income Tax Issues
Books and Records

Harwood v. Commissioner
T.C. Memo. 2022-8

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years at issue, Mr. Harwood worked as a steamfitter and brazier on construction projects in Washington and Oregon. Mr. Harwood joined Plumber and Steamfitters Local 598

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Scott St. Amand May 13, 2022
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
Penalties Under the Code
Dammit Felicia

Mathews v. Commissioner
T.C. Memo. 2021-28

On March 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-28). The primary issue presented in Mathews was whether the petitioner was entitled to car and truck expenses which were incurred driving from his residence to the location of his employer, a trucking company. General Rule in Mathews v. Commissioner As a general rule, expenses for traveling between one’s home and one’s place of business

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Scott St. Amand March 9, 2021
Business Related Issues
§ 530 of the Revenue Act of 1978

Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114)

On August 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114). The primary issue before the court in Reflectxion Resources Inc. v. Commissioner was whether the Tax Court has jurisdiction to determine whether the petitioner was entitled to relief from worker classification liabilities pursuant to § 530 of the Revenue Act of 1978. Background to Reflectxion Resources Inc. v. Commissioner The petitioner was as

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Scott St. Amand August 3, 2020
Income Tax Issues
Comparable Sales

Johnson v. Commissioner
T.C. Memo. 2020-79

On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Johnson v. Commissioner (T.C. Memo. 2020-79). The issues before the court in Johnson v. Commissioner were (1) whether the petitioner is entitled to deduct certain expenses on his Schedules F (Profit or Loss from Farming) for the years in issue; and (2) the valuation of a conservation easement. Driving Between Two Places of Business Deductible (if One is Not Your

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Scott St. Amand June 8, 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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Harwood v. Commissioner
T.C. Memo. 2022-8

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years

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Scott St. Amand May 13, 2022

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

Mathews v. Commissioner
T.C. Memo. 2021-28

On March 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-28). The primary issue presented in Mathews was whether the petitioner was entitled to car and truck expenses which were incurred driving from his residence to the location of his

Read More »
Scott St. Amand March 9, 2021

Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114)

On August 3, 2020, the Tax Court issued a Memorandum Opinion in the case of Reflectxion Resources Inc. v. Commissioner (T.C. Memo. 2020-114). The primary issue before the court in Reflectxion Resources Inc. v. Commissioner was whether the Tax Court has jurisdiction to determine whether the petitioner was entitled to relief

Read More »
Scott St. Amand August 3, 2020

Johnson v. Commissioner
T.C. Memo. 2020-79

On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Johnson v. Commissioner (T.C. Memo. 2020-79). The issues before the court in Johnson v. Commissioner were (1) whether the petitioner is entitled to deduct certain expenses on his Schedules F (Profit or Loss from Farming)

Read More »
Scott St. Amand June 8, 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

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Scott St. Amand January 15, 2020