Business Related Issues
Business Related Issues

Goldberg v. Commissioner
T.C. Memo. 2021-119

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC § 6320 or because of his nonparticipation in an even earlier

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Scott St. Amand November 3, 2021
Business Related Issues
Business Related Issues

ES NPA HOLDING LLC v. Commissioner
T.C. Memo. 2021-68

On June 3, 2021, the Tax Court issued a Memorandum Opinion in the case of ES NPA HOLDING LLC v. Commissioner (T.C. Memo. 2021-68). The primary issue presented in ES NPA HOLDING LLC v. Commissioner was whether the adjustment to ES NPA’s 2011 ordinary income originates at the level of another limited liability company, IDS, in which the petitioner held an interest, which is to say that the adjustment is a partnership item of IDS and

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Scott St. Amand June 21, 2021
Business Related Issues
Business Related Issues

New Capital Fire Inc. v. Commissioner
T.C. Memo. 2021-67

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of New Capital Fire Inc. v. Commissioner (T.C. Memo. 2021-67). The primary issue presented in New Capital Fire Inc. v. Commissioner was whether the petitioner is barred under the doctrine of equitable estoppel from changing its reporting of its bases in certain assets that the petitioner acquired in the merger because the statute of limitations bars assessment. Dancing the Merger Two Step

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Scott St. Amand June 21, 2021
Business Related Issues
Business Related Issues

Mylan Inc. v. Commissioner (156 T.C. No. 10)

On April 27, 2021, the Tax Court issued its opinion in Mylan Inc. v. Commissioner (156 T.C. No. 10). The underlying issues presented in Mylan Inc. v. Commissioner were (1) whether the legal expenses incurred in preparing notice letters to brand name drug companies of petitioner’s intent to make generic versions of its drugs as part of the FDA approval process to do the same were capital or ordinary expenses; and (2) whether the legal expenses

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Scott St. Amand June 20, 2021
Business Related Issues
Business Related Issues

Plentywood Drug Inc. v. Commissioner
T.C. Memo. 2021-45

On April 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Plentywood Drug Inc. v. Commissioner (T.C. Memo. 2021-45). The primary issues presented in Plentywood Drug, Inc. were whether the petitioner’s owners received “fair rent” or constructive dividends for the rental of the petitioner’s drug store, and whether the petitioner (a corporation) satisfied its burden to show that the IRS failed to receive prior supervisory approval for the accuracy-related penalties at

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Scott St. Amand April 26, 2021
Business Related Issues
Business Related Issues

De Los Santos v. Commissioner
156 T.C. No. 9

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos v. Commissioner was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or shareholders, and, in turn, whether such economic benefits or taxable to the petitioner’s as ordinary compensation income or as a distribution under IRC § 301.

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Scott St. Amand April 12, 2021
Business Related Issues
Business Related Issues

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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Scott St. Amand April 7, 2021
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