Business Related Issues
Business Related Issues

Olsen v. Commissioner
T.C. Memo. 2021-41

On April 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Olsen v. Commissioner (T.C. Memo. 2021-41). The primary issues presented in Olsen v. Commissioner were whether the petitioners were entitled to depreciation deductions reported on Schedules C (Profit or Loss from Business) and whether they were entitled to energy tax credits reported on Forms 3800 (General Business Credit) for deductions and credits related to a solar energy tax shelter.  Held:

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Scott St. Amand April 6, 2021
Business Related Issues
Business Related Issues

Caylor Land & Development v. Commissioner
T.C. Memo. 2021-30

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30). The primary issues presented in Caylor Land & Development v. Commissioner were whether consulting payments made between the petitioner and its microcaptive insurance company were ordinary and necessary business expenses or insurance expenses. Brief Background (to Lay a Foundation for Judge Holmes’ Puns) in Caylor Land & Development v. Commissioner The

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Scott St. Amand March 10, 2021
Business Related Issues
Tax Opinions

Estate of Warne v. Commissioner
T.C. Memo. 2021-17

On February 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Warne v. Commissioner (T.C. Memo. 2021-17). The primary issue presented in Estate of Warne v. Commissioner was whether the IRS erred in increasing the value of the estate and the LLCs and by denying a giant charitable deduction ($25 million).  Specifically, the issues in Estate of Warne v. Commissioner concerned valuation of certain family LLCs, discounts for lack

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Scott St. Amand February 18, 2021
Business Related Issues
Tax Opinions

Little Sandy Coal Co. Inc. v. Commissioner
T.C. Memo. 2021-15

On February 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Little Sandy Coal Co. Inc. v. Commissioner (T.C. Memo. 2021-15). The primary issue presented in Little Sandy Coal Co. Inc. v. Commissioner was whether the activities of the petitioner’s subsidiary’s research in developing the ships constituted elements of a process of experimentation for purposes of IRC § 41(d)(1)(C) and Treas. Reg. § 1.41-4(a)(6). Holdings, in Brief in Little Sandy Coal Co.

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Scott St. Amand February 11, 2021
Business Related Issues
Tax Opinions

Complex Media Inc. v. Commissioner
T.C. Memo. 2021-14

On February 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Complex Media Inc. v. Commissioner (T.C. Memo. 2021-14). The primary issue presented in Complex Media Inc. v. Commissioner  was whether a taxpayer was eligible to disavow the form of its transactions (an asset transfer) when the alternative form achieves a tax benefit “not inconsistent” with the taxpayer’s initial tax planning and structuring of the transactions. Background to Complex Media Inc.

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Scott St. Amand February 10, 2021
Business Related Issues
Business Related Issues

Whatley v. Commissioner
T.C. Memo. 2021-11

On January 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Whatley v. Commissioner (T.C. Memo. 2021-11). The issue presented in Whatley v. Commissioner was whether the petitioner’s tree or cattle farm (he can’t seem to decide which) was a trade or business during the years at issue. A Note on my Favorite Jurist, Judge Holmes The opinion begins by describing the petitioner as “a proud Auburn alumnus” who made the

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Scott St. Amand January 28, 2021
Business Related Issues
Tax Opinions

Costello v. Commissioner
T.C. Memo. 2021-9

On January 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Costello v. Commissioner (T.C. Memo. 2021-9). The primary issues presented in Costello v. Commissioner was whether the would-be-chicken-farmers (petitioners) were entitled to deductions for losses from farming activities, or whether the losses were startup expenses for which IRC § 195 prohibits a current deduction. Author’s Note Schadënfreude is German for happiness at the misfortune of others.  The Greek ἐπιχαιρεκακία is

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Scott St. Amand January 25, 2021
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