Business Related Issues
Business Related Issues

Treece Financial Services Group v. Commissioner
158 T.C. No. 6

On April 19, 2022, the Tax Court issued the full opinion in Treece Financial Services Group v. Commissioner (158 T.C. No. 6). The primary issue presented in Treece Financial Services Group v. Commissioner was whether the Tax Court had jurisdiction to determine whether Voluntary Classification Settlement Program (VCSP) entered into computation of taxes owed by the taxpayer. Held: Indeed, it did. Treece Financial Services Group v. Commissioner in a Nutshell Treece Financial Services Group, a

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Scott St. Amand June 14, 2022
Business Related Issues
Business Related Issues

BATS Global Markets Holdings Inc. v. Commissioner
158 T.C. No. 5

On March 31, 2022, the Tax Court issued the full opinion in BATS Global Markets Holdings Inc. v. Commissioner (158 T.C. No. 5). The primary issue presented in BATS Global Markets Holdings Inc. v. Commissioner was whether the petitioner’s transaction fees, routing fees, and logical port fees qualify as domestic production gross receipts (DPGR) for the purpose of calculating deductions pursuant to IRC § 199. Held: No dice, BATS. Procedural Background to BATS Global Markets

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Scott St. Amand June 13, 2022
Business Related Issues
Business Related Issues

TBL Licensing LLC v. Commissioner
158 T.C. No. 1

On January 31, 2022, the Tax Court issued the full opinion in TBL Licensing LLC v. Commissioner (158 T.C. No. 1). The primary issues presented in TBL Licensing LLC v. Commissioner were (a) whether the petitioner was required to recognize gain in the intangible property as a result of a reorganization, and (b) whether the reorganization was a disposition within the meaning of IRC § 367(d)(2)(A)(ii)(II). Background to TBL Licensing LLC v. Commissioner The deficiency

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Scott St. Amand June 7, 2022
Business Related Issues
Business Related Issues

Hacker v. Commissioner
(T.C. Memo. 2022-16)

On March 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Hacker v. Commissioner (T.C. Memo. 2022-16). The primary issues presented in Hacker were whether the petitioners received imputed wages and constructive dividends from their day care centers and whether the petitioners were liable for the civil fraud penalty under IRC § 6663. A Note on Hacker v. Commissioner You may remember the Hackers from two Tax Court opinions from 2021,

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Scott St. Amand May 25, 2022
Business Related Issues
Business Related Issues

Chan v. Commissioner
T.C. Memo. 2021-136

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Chan v. Commissioner (T.C. Memo. 2021-136). The primary issue presented in Chan was whether the entity in question (which filed a Form 2553, Election by a Small Business Corporation, by which it elected to be treated as an S corporation) was an S corporation or a C corporation. Background to Chan v. Commissioner The petitioners operated a restaurant in California

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Scott St. Amand April 22, 2022
Business Related Issues
Business Related Issues

Smaldino v. Commissioner
T.C. Memo. 2021-127

On November 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smaldino v. Commissioner (T.C. Memo. 2021-127). The primary issues presented in Smaldino were whether (1) the proper characterization for gift tax purposes of petitioner’s purported transfer of LLC class B member interests to Mrs. Smaldino followed by her purported retransfer of these same interests to the Dynasty Trust and (2) the fair market value of the LLC class B member

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Scott St. Amand March 31, 2022
Business Related Issues
Business Related Issues

Tribune Media Company v. Commissioner
T.C. Memo. 2021-122

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Tribune Media Company v. Commissioner (T.C. Memo. 2021-122). The primary issue presented in Tribune Media Company v. Commissioner was whether the Ricketts family (a partner of the petitioner in “Chicago Baseball Holdings, LLC”) entered into a “bona fide debt” for tax purposes. (You may remember these parties from the January 2020 decision of Chicago Baseball Holdings v. Commissioner, T.C. Memo. 2020-2).

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Scott St. Amand November 5, 2021
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