Penalties Under the Code
Tax Articles

Frivolous Taxpayers and the Jurists who Loathe Them

Frivolous taxpayers are amongst my absolute favorites.  The opinions that they spawn are just wonderful breaks in an otherwise monotonous string of upheld determinations…especially when they involve crazy German nationals, as no less than three did in 2020.  In this article, we examine the frivolous return penalty (IRC § 6702) and the frivolous petition penalty (IRC § 6673(a)(1)).  In doing so, we include a discussion of some of the taxpayers that made 2020 so much

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Scott St. Amand April 15, 2021
Tax Articles

Substantiation of Charitable Contributions Under DEFRA

The deductibility of a charitable contribution depends on the donor-taxpayer meeting several conditions, which conditions are determined by the size and type of contribution.  The larger the contribution, the more stringent the documentation and substantiation that is needed.[1]  With respect to non-cash donations, the amount of the contribution is generally equal to the fair market value of the property at the time of contribution.[2] Determining the FMV, however, is the factor that taxpayers so often

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Scott St. Amand March 2, 2021
Tax Articles

No Charitable Exemption for Medical Marijuana Nonprofits

Uncle Bill is a child of the Sixties. He is told you the story many a time how the lead singer for the Zombies stole his Beatle boots when they played at Old Orchard Beach the summer when he was 17. When Bill calls you out of the blue to discuss a hypothetical charitable exemption for medical marijuana nonprofits, you assume his interest is more than simply academic. After all, as Bill describes it, he

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Scott St. Amand February 8, 2021
Tax Articles

No Charitable Exemption for an Organization Formed to Support One Individual

Explaining the most simple tax concepts to Uncle Bill is a task requiring herculean patience.  Explaining why there will be no charitable exemption for an organization formed to support one individual, even if said individual is his current favorite son, Leroy, left you with a deficit of patience that will not be soon refilled. Background Cousin Leroy is not entirely sure what happened. From what he can remember before he blacked out, he turned the

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Scott St. Amand February 3, 2021
Income Tax Issues
Income Tax Issues

Deductibility of Fines and Penalties under New IRC § 162(f) Regulations

As you sat down one fine Tuesday morning in January 2021, and you cycled through the emails that rolled into your inbox in the 12 minutes since you last checked them, you notice an update announcing that the IRS is issued final regulations on IRC § 162(f) – deductibility of fines and penalties. You have had prior experience with the Code section, due to Uncle Bill’s penchant for minor violations of laws, regulations, and social

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Scott St. Amand February 1, 2021
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Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request

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Scott St. Amand January 24, 2023

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

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Scott St. Amand November 23, 2022