Income Tax Issues

Delgado v. Commissioner (T.C. Memo. 2021-84)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade or business” as defined by IRC § 7701(a)(26) held any water… Quick Work of the Frivolousness Compensation for services is included in gross income. IRC

Read More »
Income Tax Issues

Geiman v. Commissioner (T.C. Memo. 2021-80)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Geiman v. Commissioner (T.C. Memo. 2021-80). The primary issue presented in Geiman was whether the petitioner was a tax “itinerant” or whether he had a tax home, for purposes of unreimbursed business expenses. Background The petitioner is a union electrician who spent most of 2013 on jobs in various parts of Wyoming and Colorado. He claimed on his 2013 Federal

Read More »
Income Tax Issues

Nurumbi v. Commissioner (T.C. Memo. 2021-79)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Nurumbi v. Commissioner (T.C. Memo. 2021-79). The primary issue presented in Nurumbi was whether the petitioner was subject to the heightened substantiation rules under IRC § 274(d), or whether the exception to such rules for vehicles for hire applied. Held:  Background The petitioner was an Uber pimp. He maintained a stable of Uber drivers under his iron fist and gold

Read More »
Income Tax Issues

Holliday v. Commissioner (T.C. Memo. 2021-69)

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background Two lawsuits are central to this case. The first is petitioner’s divorce proceeding, in which she was represented by J. Beverly and his law firm (divorce attorney and malpractice defendants, respectively). The second is petitioner’s malpractice

Read More »
Income Tax Issues

Torres v. Commissioner (T.C. Memo. 2021-66)

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to IRC § 165. Background As of 2016, the petitioner was illiterate—whether because of an illness or because he didn’t ascribe much to them book learnings,

Read More »
Income Tax Issues

Grossman v. Commissioner (T.C. Memo. 2021-65)

On May 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Grossman v. Commissioner (T.C. Memo. 2021-65). The primary issue presented in Grossman was whether state law determines a taxpayer’s marital status at death for purposes of the marital deduction under IRC § 2056(a). The Saga of Semone All Semone Grossman wanted was to find a nice Jewish girl to settle down with. He had survived internment in a series of

Read More »
Income Tax Issues

Estate of Jackson v. Commissioner (T.C. Memo. 2021-48)

On May 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Jackson v. Commissioner (T.C. Memo. 2021-48). Two primary issues were dealt with in this gargantuan (271 pages) opinion by Judge Holmes.  The primary issue was the valuation of three contested assets, Michael Jackson’s image and likeness, and the estate’s interest in two trusts through which the estate held an interest in Sony/ATV Publishing and an interest in Mijac

Read More »
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular posts:

The Truth about Amending Tax Returns

Clients are untrustworthy.  As a tax controversy attorney, this is my experience. I have heard that other types of law deals with more honorable sorts, but I’ll believe it when I see it.  When a client comes to you and says “whoopsie, I forgot to report [insert absurdly large number

Read More »

Mathews v. Commissioner (T.C. Memo. 2021-85)

On July 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-85). The primary issue presented in Mathews was whether the Tax Court had jurisdiction to hear a petitioner when the pro se petitioner filed his petition (sent a letter to

Read More »

Delgado v. Commissioner (T.C. Memo. 2021-84)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Delgado v. Commissioner (T.C. Memo. 2021-84). The primary issue presented in Delgado was whether the petitioner’s frivolous argument that he did not receive taxable income in 2017 because he was not engaged in a “trade

Read More »

Peterfreund v. Commissioner (T.C. Memo. 2021-83)

On July 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Peterfreund v. Commissioner (T.C. Memo. 2021-83). The primary issue presented in Peterfreund was whether the IRS’s Whistleblower Office (WBO) abused its discretion because it did not initiate an administrative or judicial action and it did

Read More »

Pragias v. Commissioner (T.C. Memo. 2021-82)

On June 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Pragias v. Commissioner (T.C. Memo. 2021-82). The primary issue presented in Pragias was whether the six-year statute of limitations under IRC § 6501(e) (substantial omission of items) applied. The Substantial Omission Extension under IRC §

Read More »