Penalties Under the Code
Amended Returns

Harrington v. Commissioner
T.C. Memo. 2021-95

  On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC § 6501(a), or whether the statute of limitations remained open due to fraud under IRC § 6501(c)(1). Summary1 “Sarah, I feel like I don’t even know you.” “It’s Vivian. Would

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Income Tax Issues
Deductions

Nurumbi v. Commissioner
T.C. Memo. 2021-79

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi v. Commissioner was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for vehicles for hire applied. Held:  Background to Nurumbi v. Commissioner The petitioner was an Uber pimp. He maintained a stable of Uber drivers

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Income Tax Issues
Bank Deposits Analysis

Haghnazarzadeh v. Commissioner
T.C. Memo. 2021-47

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh v. Commissioner was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context to Haghnazarzadeh v. Commissioner This is an unreported income case, and the opinion is all of six pages long.  One has expectations of a couple thousand

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Business Related Issues
Burden of Proof

Berry v. Commissioner
T.C. Memo. 2021-42

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry v. Commissioner were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether the petitioners are entitled to certain claimed deductions, and whether the petitioners are liable for accuracy-related penalties under IRC § 6662. Background to Berry v.

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Penalties Under the Code
Accuracy Related Penalty

Walton v. Commissioner
T.C. Memo. 2021-40

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background to Walton v. Commissioner The petitioner was a New Yorker,[1] who failed to report $170,000 in nonemployee compensation in 2015. Strike one and two. The petitioner was terminated from her

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Income Tax Issues
Bank Deposits Analysis

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for filing (very) late and for being (very) negligent and for (very) substantially understating their liabilities. Background to NOLs in Martin v. Commissioner The

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Harrington v. Commissioner
T.C. Memo. 2021-95

  On July 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Harrington v. Commissioner (T.C. Memo. 2021-95). The primary issue presented in Harrington was whether the IRS’s assessment was assessment is barred by the three-year period of limitations in IRC § 6501(a), or whether the

Read More »

Nurumbi v. Commissioner
T.C. Memo. 2021-79

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi v. Commissioner was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such

Read More »

Haghnazarzadeh v. Commissioner
T.C. Memo. 2021-47

On April 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Haghnazarzadeh v. Commissioner (T.C. Memo. 2021-47). The primary issue presented in Haghnazarzadeh v. Commissioner was whether certain deposits into the petitioners’ nine bank accounts are ordinary income or nontaxable deposits. A Bit of Context to

Read More »

Berry v. Commissioner
T.C. Memo. 2021-42

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry v. Commissioner were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether

Read More »

Walton v. Commissioner
T.C. Memo. 2021-40

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background to Walton v. Commissioner The

Read More »

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for

Read More »