Income Tax Issues
Tax Opinions

James v. Commissioner (T.C. Memo. 2021-7)

On January 13, 2021, the Tax Court issued a Memorandum Opinion in the case of James v. Commissioner (T.C. Memo. 2021-7). The issue presented in James v. Commissioner was whether the petitioner was entitled to innocent spouse relief under IRC § 6015(e)(1). A Tangled Marital Web in James v. Commissioner The petitioner was married to her husband from 2003 until 2006. Nevertheless, the petitioner lived with her husband in 2010, when the petitioner went through

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Scott St. Amand January 13, 2021
Income Tax Issues
Tax Opinions

Kelley v. Commissioner
T.C. Memo. 2021-2

On January 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Kelley v. Commissioner (T.C. Memo. 2021-2). The issue presented in Kelley v. Commissioner was whether the provisions of IRC § 86(c) violated his Constitutional due process rights…and “various other constitutional arguments” that the Tax Court did not deign to address. Preface to Kelley v. Commissioner Anyone who has read Briefly Taxing for any length of time—you know who you are—knows

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

Lashua v. Commissioner
T.C. Memo. 2020-151

On November 9, 2020, the Tax Court issued a Memorandum Opinion in the case Lashua v. Commissioner (T.C. Memo. 2020-151). The primary issues before the court in Lashua v. Commissioner were whether the petitioner had unreported retirement income, whether the petitioner was liable for additional tax under IRC § 72(t), and whether the petitioner received a valid notice of deficiency.  A further issue was whether the petitioner was completely full of shit.  Judge Marvel –

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Scott St. Amand November 9, 2020
Income Tax Issues
Tax Opinions

Leith v. Commissioner
T.C. Memo. 2020-149

On November 4, 2020, the Tax Court issued a Memorandum Opinion in the case Leith v. Commissioner (T.C. Memo. 2020-149). The primary issue before the court in Leith v. Commissioner was whether the petitioner is entitled to IRC § 6015(f) equitable innocent spouse relief to the extent of the tax items attributable to her ex-husband for the years at issue, even though her ex-husband (the intervenor) opposed the relief.

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Scott St. Amand November 4, 2020
Income Tax Issues
Tax Opinions

Sharma v. Commissioner
T.C. Memo. 2020-147

On October 29, 2020, the Tax Court issued a Memorandum Opinion in the case of Sharma v. Commissioner (T.C. Memo. 2020-147). The primary issue before the court in Sharma v. Commissioner was what portion of the petitioners’ loss deduction from rental real estate activities claimed on Schedule E (Supplemental Income and Loss), is disallowed under the IRC § 469(a) and (i) limitations on the deductibility of passive activity losses.

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Scott St. Amand October 29, 2020
Income Tax Issues
Tax Opinions

Coleman v. Commissioner
T.C. Memo. 2020-146

On October 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Coleman v. Commissioner (T.C. Memo. 2020-146). The primary issue before the court in Coleman v. Commissioner was whether the petitioner could substantiate that he sustained a large gambling loss ($350,000).

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Scott St. Amand October 22, 2020
Income Tax Issues
Tax Opinions

Giambrone v. Commissioner
T.C. Memo. 2020-145

On October 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Giambrone v. Commissioner (T.C. Memo. 2020-145). The primary issue before the court in Giambrone v. Commissioner is whether the IRS improperly disallowed a theft loss deduction that the petitioners claimed on their respective 2012 returns.

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Scott St. Amand October 19, 2020
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