Business Related Issues
Tax Opinions

Aspro Inc. v. Commissioner
T.C. Memo. 2021-8

On January 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Aspro Inc. v. Commissioner (T.C. Memo. 2021-8). The sole issue presented in Aspro Inc. v. Commissioner was whether the petitioner was entitled to deductions for management fees paid to three shareholders. Background to Aspro Inc. v. Commissioner I find the petitioner suspect.  First off, it is an Iowa C corporation, but it is not involved with the production or processing of

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Scott St. Amand January 21, 2021
Business Related Issues
Tax Opinions

Filler v. Commissioner
T.C. Memo. 2021-6

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Filler v. Commissioner (T.C. Memo. 2021-6). The issues presented in Filler v. Commissioner were whether the petitioner (1) properly reported $100,000 in income received as capital gain rather than ordinary income; (2) is liable for self-employment tax; (3) is entitled to deduct a net operating loss carryover originating in tax year 2012; and (4) is liable for penalty under IRC

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Scott St. Amand January 13, 2021
Business Related Issues
Tax Opinions

Hohl et al. v. Commissioner
T.C. Memo. 2021-5

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Hohl et al. v. Commissioner (T.C. Memo. 2021-5). The issue presented in Hohl et al. v. Commissioner was whether failure to repay loans provided to a partnership by a partner, which the partnership treated as contributions upon dissolution, resulted in cancellation of indebtedness income. Background to Hohl et al. v. Commissioner Hohl, Blake, and Bowles were partners in a partnership

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Scott St. Amand January 13, 2021
Business Related Issues
Tax Opinions

Tangel et al. v. Commissioner
T.C. Memo. 2021-1

On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Tangel et al. v. Commissioner (T.C. Memo. 2021-1). The issue presented in the consolidated Tangel et al. v. Commissioner cases was whether the petitioners were entitled to qualified research expense credits under IRC § 41. Background to Tangel et al. v. Commissioner The petitioners’ S corporation, Enercon, designs and produces integrated controls and switchgears for the power generation industry.  It

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Scott St. Amand January 11, 2021
Income Tax Issues
Tax Opinions

Watts v. Commissioner
T.C. Memo. 2020-144

On October 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Watts v. Commissioner (T.C. Memo. 2020-143). The issues before the court in Watts v. Commissioner were (1) whether the “Danielson rule” applies to limit the invocation of the substance-over-form doctrine by taxpayers in certain cases; and (2) if so, whether petitioners proved that the Watts family had a separate, enforceable oral agreement with Wellspring that predated the purchase by Sun

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Scott St. Amand October 15, 2020
Business Related Issues
Tax Opinions

Morning Star Packing Company L.P. v. Commissioner
T.C. Memo. 2020-142

On October 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Morning Star Packing Company L.P. v. Commissioner (T.C. Memo. 2020-141). The issues before the court in Morning Star Packing Company L.P. v. Commissioner. were whether the accrued production costs were: (1) fixed and binding where economic performance did not occur until the year following the tax year claimed for and (2) whether the partnerships’ inclusion of such production costs in

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Scott St. Amand October 14, 2020
Business Related Issues
Tax Opinions

Lucero v. Commissioner
T.C. Memo. 2020-136

On September 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Lucero v. Commissioner (T.C. Memo. 2020-136). The issue before the court in Lucero v. Commissioner was whether the petitioners’ real estate loss deductions were disallowed by IRC § 469 and/or IRC § 280A. Background to Lucero v. Commissioner The petitioner-husband owned a short-term rental property in The Sea Ranch, California. To be clear, the property was not in Sea Ranch,

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Scott St. Amand September 29, 2020
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