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
Income Tax Issues
Tax Opinions

Wienke v. Commissioner
T.C. Memo. 2020-143

On October 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Wienke v. Commissioner (T.C. Memo. 2020-143). The issues before the court in Wienke v. Commissioner are numerous and varied; in fact, the Tax Court lists eight specific, separate issues.

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Scott St. Amand October 14, 2020
Income Tax Issues
Tax Opinions

Robinson v. Commissioner
T.C. Memo. 2020-134

On September 23, 2020, the Tax Court issued a Memorandum Opinion in the case of Robinson v. Commissioner (T.C. Memo. 2020-134). The primary issue before the court in Robinson v. Commissioner was whether the petitioner was entitled to equitable relief from joint and several liability (innocent spouse relief) associated with a joint return from 2010.

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Scott St. Amand September 23, 2020
Income Tax Issues
Tax Opinions

Savedoff v. Commissioner
T.C. Memo. 2020-125

On August 31, 2020, the Tax Court issued a Memorandum Opinion in the case of Savedoff v. Commissioner (T.C. Memo. 2020-125). The primary issues before the court in Savedoff were whether the petitioner received proper notice of the Notice of Federal Tax Lien filing and whether the IRS abused its discretion in its ultimate determination against the petitioner. Background to Savedoff v. Commissioner The petitioner is a self-employed attorney. Although she filed income tax returns

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Scott St. Amand August 31, 2020
Income Tax Issues
Tax Opinions

TGS-NOPEC Geophysical Company v. Commissioner
155 T.C. No. 3

On August 26, 2020, the Tax Court issued its opinion in TGS-NOPEC Geophysical Company v. Commissioner (155 T.C. No. 3). The primary issue presented in TGS-NOPEC Geophysical Company v. Commissioner is whether the IRS’s disallowance of petitioner’s deduction for income attributable to domestic production activities pursuant to IRC § 199 was appropriate. Business Background in TGS-NOPEC Geophysical Company v. Commissioner The petitioner is engaged in the business of acquires, processes, and licenses marine seismic data. Raw

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Scott St. Amand August 26, 2020
Income Tax Issues
Tax Opinions

Swanberg v. Commissioner
T.C. Memo. 2020-123

On August 25, 2020, the Tax Court issued a Memorandum Opinion in the case of Swanberg v. Commissioner (T.C. Memo. 2020-123). The primary issue before the court in Swanberg v. Commissioner was whether the IRS abused its discretion in failing to consider the petitioner’s prior year credits in determining liability for the year under examination. Availability of Credit in Swanberg v. Commissioner If your client’s primary argument to avoid liability in year at issue is

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Scott St. Amand August 25, 2020
Income Tax Issues
Tax Opinions

Brashear v. Commissioner
T.C. Memo. 2020-122

On August 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Brashear v. Commissioner (T.C. Memo. 2020-122). The primary issue before the court in Brashear was whether the petitioners were entitled to various deductions on Schedule C (Profits and Loss from Business). Business-Related Deductions 101 in Brashear v. Commissioner The taxpayer’s burden of proof regarding entitlement to deductions requires the taxpayer to substantiate all expenses underlying the deductions claimed by keeping

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Scott St. Amand August 19, 2020
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