Income Tax Issues
Anticipatory Assignment of Income Doctrine

Deductibility of Non-Professional Attendant Care Provided by a Family Member

Uncle Bill took a nasty turn on the forklift at work a couple of months back.  That Bill was in a motorized vehicle-related accident came as little shock to your delicate system, after all Bill was (and still is, to your knowledge) the only person in the history of Biddeford, Maine to ever get a DUI on a lawnmower, but he paid for the mayor’s peonies (scattered like the remnants of a ticker-tape parade across

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Scott St. Amand April 29, 2021
Income Tax Issues
Aunt Ethel

Loss of Consortium Damages Excludable under IRC § 104(a)(2)

A couple of years back, Uncle Bill was in an unfortunate forklift accident.  Bill filed a lawsuit in Maine, where the accident occurred, and in the complaint, Bill alleged that the injuries and damages suffered were the result of acts of negligence, reckless, willful and/or wanton acts of the tannery for whom Bill was employed. The lawsuit requested damages for economic injuries (medical bills), for noneconomic injuries of mental anguish, loss of enjoyment of life,

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Scott St. Amand April 29, 2021
Income Tax Issues
Abandonment

Reckless (albeit Tax Conscious) Abandonment under IRC § 165

Uncle Bill is somewhat of a hoarder.  In truth, the only thing that he has ever abandoned was his first wife…in a Waffle House at 2:15 AM on the outskirts of Norman, Oklahoma. In Bill’s defense, she had tried to stab him. In her defense, he probably deserved it. When Bill comes to you to chat about IRC § 165 losses—so-called “abandonment” losses—you know he has some hairbrained scheme in his head to stick it

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Scott St. Amand April 29, 2021
Procedural Issues
Aunt Ethel

Extinguishment of Liens on Defeasible Property

A part of you couldn’t be happier that Uncle Bill obtained the services of another lawyer for one of his stick-it-to-the-man schemes. In this case, Bill wanted to avoid probate and transfer his home in Dixie County, Florida to his son Jethro. Bill and Ethel, however, still wanted to live in the house and wanted to be able to sell the house if Jethro pissed them off, which, in your experience, was a foregone conclusion.

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Scott St. Amand April 29, 2021
Income Tax Issues
Alter Ego Liability

Successor Liability in a Purchase of Corporate Assets

As a tax controversy lawyer, most of your clients come to you in quite a predicament with the IRS, rather than coming to you to avoid said predicament. Such is the case when Cousin Elmer comes to visit you one dismal winter day. You may remember Elmer from our article on FBARs, but if not, Cousin Elmer has seven and a half fingers from trying, rather unsuccessfully, to eradicate his attic’s squirrel population through the

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Scott St. Amand April 29, 2021
Procedural Issues
Accuracy Related Penalty

Reasonable Reliance on a Competent Advisor

Explaining Reasonable Reliance on a Competent Advisor to Uncle Bill. Reasonable cause, specifically, reasonable reliance on a competent advisor will prove rather important to Uncle Bill, and so when he calls you to discuss this great scheme plan he’s been introduced to, you know that this is the time to breach the subject with Bill. You see, Uncle Bill bought his first house from an infomercial he saw after the Ed Sullivan show in the mid-1960s. 

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Scott St. Amand April 19, 2021
Charities

Bad News Regarding Religious Tax Exemptions: Peyote is not a “Sacrament”

You can fault Cousin Jedediah for many things—many things—but charisma is not amongst them. It turns out that Jed has developed something of a following. He assures you that it is not a cult, which you have to imagine are the first words out of every cult leader’s mouth when questioned about it. Having drank Jed’s Kool-Aid, the members of his new religious “order” follow him around like willing lambs, but they have made musings

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Scott St. Amand April 16, 2021
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Loss of Consortium Damages Excludable under IRC § 104(a)(2)

A couple of years back, Uncle Bill was in an unfortunate forklift accident.  Bill filed a lawsuit in Maine, where the accident occurred, and in the complaint, Bill alleged that the injuries and damages suffered were the result of acts of negligence, reckless, willful and/or wanton acts of the tannery

Read More »
Scott St. Amand April 29, 2021

Extinguishment of Liens on Defeasible Property

A part of you couldn’t be happier that Uncle Bill obtained the services of another lawyer for one of his stick-it-to-the-man schemes. In this case, Bill wanted to avoid probate and transfer his home in Dixie County, Florida to his son Jethro. Bill and Ethel, however, still wanted to live

Read More »
Scott St. Amand April 29, 2021

Successor Liability in a Purchase of Corporate Assets

As a tax controversy lawyer, most of your clients come to you in quite a predicament with the IRS, rather than coming to you to avoid said predicament. Such is the case when Cousin Elmer comes to visit you one dismal winter day. You may remember Elmer from our article

Read More »
Scott St. Amand April 29, 2021

Reasonable Reliance on a Competent Advisor

Explaining Reasonable Reliance on a Competent Advisor to Uncle Bill. Reasonable cause, specifically, reasonable reliance on a competent advisor will prove rather important to Uncle Bill, and so when he calls you to discuss this great scheme plan he’s been introduced to, you know that this is the time to breach

Read More »
Scott St. Amand April 19, 2021