Business Related Issues
Tax Opinions

Simpson v. Commissioner
T.C. Memo. 2020-100

On July 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Simpson v. Commissioner (T.C. Memo. 2020-100). The issue before the court in Simpson v. Commissioner was whether the petitioners were allowed deductions for unreimbursed partnership expenses (2012-2014) and unreimbursed employee business expenses (2014), which deductions were adjusted in the IRS’s amended answer. Background to Simpson v. Commissioner The IRS issued the petitioners a notice of deficiency for tax years 2012,

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Scott St. Amand July 7, 2020
Business Related Issues
Tax Opinions

Santos v. Commissioner
T.C. Memo. 2020-88

On June 17, 2020, the Tax Court issued a Memorandum Opinion in the case of Santos v. Commissioner (T.C. Memo. 2020-88). The sole issue before the court in Santos v. Commissioner was whether the individuals listed on the notice of determination should be legally classified as employees (IRS’s position) or as independent contractors (petitioner’s position). The Entrepreneurial Housekeeper in Santos v. Commissioner The petitioner was born and raised in Brazil and moved to the U.S.

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Scott St. Amand June 17, 2020
Business Related Issues
Tax Opinions

Sellers v. Commissioner (T.C. Memo. 2020-84)

On June 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Sellers v. Commissioner (T.C. Memo. 2020-84). The primary issue before the court in Sellers v. Commissioner was whether the petitioner provided sufficient evidence to substantiate his bases in certain companies and his material participation (for passive activity loss purposes). This case also presents a very interesting question of whether the burden of proof really shifts to the IRS to prove

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

Gluck v. Commissioner
T.C. Memo. 2020-66

On May 26, 2020, the Tax Court issued a Memorandum Opinion in the case of Gluck v. Commissioner (T.C. Memo. 2020-65). The issues before the court in Gluck v. Commissioner were (1) whether the Tax Court had jurisdiction to redetermine a deficiency based upon an adjustment disallowing like-kind exchange treatment, which was a “computational adjustment” within the meaning of IRC § 6231(a)(6); and (2) whether the Tax Court nevertheless had jurisdiction to redetermine the penalty

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Scott St. Amand May 26, 2020
Business Related Issues
Tax Opinions

NCA Argyle LP v. Commissioner
T.C. Memo. 2020-56

On May 13, 2020, the Tax Court issued a Memorandum Opinion in the case of NCA Argyle LP v. Commissioner (T.C. Memo. 2020-56). The basic issue before the court in NCA Argyle LP v. Commissioner was whether proceeds received from the settlement of a lawsuit involving punitive damages which proceeds were received in exchange for the plaintiff/taxpayer’s interests in joint ventures (a capital asset) were properly treated as gain on the sale of a capital

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Scott St. Amand May 13, 2020
Business Related Issues
Business Related Issues

Richmond Patients Group v. Commissioner
T.C. Memo. 2020-52

On May 4, 2020, the Tax Court issued a Memorandum Opinion in the case of Richmond Patients Group v. Commissioner (T.C. Memo. 2020-52). The issues before the court in Richmond Patients Group v. Commissioner were (1) whether the petitioner is entitled to additional costs of goods sold or deductions for business expenses; (2) whether the petitioner was a reseller or a producer of marijuana pursuant to IRC § 471 during the years in issue; (3) whether

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Scott St. Amand May 4, 2020
Business Related Issues
Tax Opinions

Bridges v. Commissioner
T.C. Memo. 2020-51

On April 27, 2020, the Tax Court issued a Memorandum Opinion in the case of Bridges v. Commissioner (T.C. Memo. 2020-51). The issue before the court in Bridges v. Commissioner was whether the IRS appropriately relied on IRC § 6231(g)(2) in determining that TEFRA procedures did not apply to the petitioner’s LLC. TEFRA’s Application to Partnerships Appearing “Small” IRC § 6231(a)(1)(A) generally applies the TEFRA provisions to any entity that is required to file a

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Scott St. Amand April 27, 2020
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