Income Tax Issues
Income Tax Issues

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied; and (ii) whether the taxpayer was entitled to itemized deductions when he failed to file a return, and the IRS filed a substitute for return

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Scott St. Amand November 23, 2022
Income Tax Issues
Income Tax Issues

Villanueva v. Commissioner
T.C. Memo. 2022-27

On March 31, 2022, the Tax Court issued a Memorandum Opinion in the case of Villanueva v. Commissioner (T.C. Memo. 2022-27). The primary issue presented in Villanueva v. Commissioner was whether the petitioner was entitled to a net operating loss deduction. Held: Sorry, Edgardo, not today. Background to Villanueva v. Commissioner The IRS determined deficiencies against the petitioner for 2013 and 2014 of $61,832 and $90,408, respectively, and an IRC § 6662(a) accuracy-related penalty and

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Scott St. Amand November 21, 2022
Income Tax Issues
Income Tax Issues

Sherwin Community Painters Inc. v. Commissioner
T.C. Memo. 2022-19

On March 9, 2022, the Tax Court issued a Memorandum Opinion in the case of Sherwin Community Painters Inc. v. Commissioner (T.C. Memo. 2022-19). The primary issues presented in Sherwin Community Painters Inc. v. Commissioner were whether the taxpayer was entitled to certain substantiated certain expenses it claimed were “ordinary and necessary business expenses” and whether Swanette Ward received constructive dividends from Sherwin. Also at issue is how obstinate the IRS can actually be. (Hint:

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Scott St. Amand June 8, 2022
Income Tax Issues
Income Tax Issues

Walters v. Commissioner
(T.C. Memo. 2022-17)

On March 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Walters v. Commissioner (T.C. Memo. 2022-17). The primary issue presented in Walters v. Commissioner was whether the petitioners’ mutually owned partnership was engaged in for-profit activities in constructing “green” homes. Background to Walters v. Commissioner Petitioner Jessica Walters (petitioner daughter) resided in North Carolina when she timely filed her petition, and petitioners David Walters (petitioner husband) and Jean Walters (petitioner

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Scott St. Amand May 26, 2022
Income Tax Issues
Income Tax Issues

Clary Hood Inc. v. Commissioner
T.C. Memo. 2022-15

On March 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Clary Hood Inc. v. Commissioner (T.C. Memo. 2022-15). The primary issue presented in Clary Hood Inc. was the amount the petitioner may deduct under IRC § 162(a)(1) as reasonable compensation paid to its chief executive officer (CEO) and shareholder Clary L. Hood (Mr. Hood) during the years at issue. Background to Clary Hood Inc. v. Commissioner According to Judge Greaves

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Scott St. Amand May 24, 2022
Income Tax Issues
Income Tax Issues

Lord v. Commissioner
T.C. Memo. 2022-14

On March 1, 2022, the Tax Court issued a Memorandum Opinion in the case of Lord v. Commissioner (T.C. Memo. 2022-14). The primary issue presented in Lord was whether the tax depreciation methods for inventory production assets can be used under either section 263A or section 471 when section 280E is applied. Holding: In a battle of Lord versus the IRS, one would think the almighty would prevail. Turns out, not so. Background to Lord

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Scott St. Amand May 23, 2022
Income Tax Issues
Income Tax Issues

Hicks v. Commissioner
T.C. Memo. 2022-10

On February 23, 2022, the Tax Court issued a Memorandum Opinion in the case of Hicks v. Commissioner (T.C. Memo. 2022-10). The primary issue presented in Hicks v. Commissioner was whether the petitioner was entitled to the dependency exemption deductions and child tax credits claimed on his income tax return. Background to Hicks v. Commissioner The petitioner has two children with one Ms. Oddimissia N. Johnson who were minors in 2014, the year at issue.

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Scott St. Amand May 17, 2022
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Guest Post: Ultimate Guide to Managing Business Finances for Entrepreneurs

Guest Writer:  Michael Longsdon of ElderFreedom.net* As an entrepreneur, managing the finances of your business can be a daunting task, which is why this Guide to Managing Business Finances for Entrepreneurs was created. It is not uncommon to feel overwhelmed, especially if you lack experience in finance. However, good financial

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Scott St. Amand June 26, 2023

Norberg v. Commissioner
T.C. Memo. 2022-30

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Norberg v. Commissioner (T.C. Memo. 2022-30). The primary issue presented in Norberg v. Commissioner was whether the settlement officer abused its discretion in upholding a notice of intent to levy and denying the petitioners’ request

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Scott St. Amand January 24, 2023

Salter v. Commissioner
T.C. Memo. 2022-29

On April 5, 2022, the Tax Court issued a Memorandum Opinion in the case of Salter v. Commissioner (T.C. Memo. 2022-29). The primary issues presented in Salter v. Commissioner were (i) whether the Code section providing exception from imposition of additional tax resulting from early distribution from retirement plan applied;

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Scott St. Amand November 23, 2022

Middleton v. Commissioner
T.C. Memo. 2022-28

On April 4, 2022, the Tax Court issued a Memorandum Opinion in the case of Middleton v. Commissioner (T.C. Memo. 2022-28). The primary issues presented in Middleton v. Commissioner were (i) whether the taxpayer could challenge the Trust Fund Recovery Penalty at his CDP hearing; and (ii) whether the taxpayer

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Scott St. Amand November 22, 2022

Villanueva v. Commissioner
T.C. Memo. 2022-27

On March 31, 2022, the Tax Court issued a Memorandum Opinion in the case of Villanueva v. Commissioner (T.C. Memo. 2022-27). The primary issue presented in Villanueva v. Commissioner was whether the petitioner was entitled to a net operating loss deduction. Held: Sorry, Edgardo, not today. Background to Villanueva v.

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Scott St. Amand November 21, 2022

Golditch v. Commissioner
T.C. Memo. 2022-26

On March 29, 2022, the Tax Court issued a Memorandum Opinion in the case of Golditch v. Commissioner (T.C. Memo. 2022-26). The primary issues presented in Golditch v. Commissioner were (i) whether the taxpayer was permitted to challenge his underlying tax liability at CDP hearing; (ii) whether the taxpayer’s argument

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Scott St. Amand November 18, 2022