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
Business Related Issues
Burden of Proof

Simpson v. Commissioner
T.C. Memo. 2020-100

On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions were adjusted in the IRS’s amended answer. Background to Simpson v. Commissioner The IRS issued the petitioners a notice of deficiency for tax years 2012,

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Scott St. Amand July 7, 2020
Income Tax Issues
IRC § 162

Thoma v. Commissioner
T.C. Memo. 2020-67

On May 27, 2020, the Tax Court issued a Memorandum Opinion in the case of Thoma v. Commissioner (T.C. Memo. 2020-67). Although there are a number of sub-issues related to whether the petitioner-husband (PH) was an employee or independent contractor, including deductibility of medical and business expenses, the core issue in Thoma v. Commissioner boils down to the age old question of whether PH was an employee or independent contractor of an accounting firm. Brief

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Scott St. Amand May 27, 2020
Income Tax Issues
Books and Records

Near v. Commissioner
T.C. Memo. 2020-10

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near v. Commissioner was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for work when the employee had a right to seek reimbursement from his employer. Ordinary and Necessary Business Expenses under IRC § 162 in Near v.

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Scott St. Amand January 14, 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

Read More »
Scott St. Amand May 13, 2022

Simpson v. Commissioner
T.C. Memo. 2020-100

On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions

Read More »
Scott St. Amand July 7, 2020

Thoma v. Commissioner
T.C. Memo. 2020-67

On May 27, 2020, the Tax Court issued a Memorandum Opinion in the case of Thoma v. Commissioner (T.C. Memo. 2020-67). Although there are a number of sub-issues related to whether the petitioner-husband (PH) was an employee or independent contractor, including deductibility of medical and business expenses, the core issue

Read More »
Scott St. Amand May 27, 2020

Near v. Commissioner
T.C. Memo. 2020-10

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Near v. Commissioner (T.C. Memo. 2020-10). The issue presented in Near v. Commissioner was whether the petitioner, an attorney for a public utility in California, could deduct unreimbursed employee business expenses incurred while travelling for

Read More »
Scott St. Amand January 14, 2020