Income Tax Issues
Tax Opinions

Sham v. Commissioner
T.C. Memo. 2020-119

On August 12, 2020, the Tax Court issued a Memorandum Opinion in the case of Sham v. Commissioner (T.C. Memo. 2020-119). The primary issues before the court in Sham v. Commissioner were whether the petitioner had (or could) substantiate significant itemized deductions, business deductions, and other “miscellaneous” deductions, and (2) whether the petitioner had failed to report (or maintain records of) her gross receipts. Introductory Note to Sham v. Commissioner My dad ran political campaigns

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Scott St. Amand August 12, 2020
Income Tax Issues
Tax Opinions

Bethune v. Commissioner
T.C. Memo. 2020-96

On June 30, 2020, the Tax Court issued a Memorandum Opinion in the case of Bethune v. Commissioner (T.C. Memo. 2020-96). The primary issue before the court in Bethune v. Commissioner was whether an official signed statement by the custodial parent giving up the right to claim the child as a dependent on his tax return, which statement was not attached to the noncustodial parent’s return, would support a dependency exemption deduction, the child tax

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Scott St. Amand June 30, 2020
Income Tax Issues
Tax Opinions

Rogers v. Commissioner
T.C. Memo. 2020-91

On June 18, 2020, the Tax Court issued a Memorandum Opinion in the case of Rogers v. Commissioner (T.C. Memo. 2020-91). The issue before the court in Rogers v. Commissioner was whether the petitioner-wife was eligible for innocent spouse relief pursuant to IRC § 6015(b), and, if not, whether she should be granted relief pursuant to IRC § 6015(f). A (Not So) Beautiful Day in the Neighborhood in Rogers v. Commissioner The petitioners, Mr. and

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Scott St. Amand June 18, 2020
Income Tax Issues
Tax Opinions

Abrego v. Commissioner
T.C. Memo. 2020-87

On June 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Abrego v. Commissioner (T.C. Memo. 2020-87). The issue before the court in Abrego v. Commissioner was whether the petitioners received excess advance payments of the premium assistance tax credit (commonly known as the premium tax credit or PTC) allowed under section 1412 of the Patient Protection and Affordable Care Act, which in turn increased their tax due by the amount

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Scott St. Amand June 16, 2020
Income Tax Issues
Tax Opinions

Bidzimou v. Commissioner
T.C. Memo. 2020-85

On June 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Bidzimou v. Commissioner (T.C. Memo. 2020-85). The primary issue before the court in Bidzimou v. Commissioner was whether a state court’s order awarding the petitioner the right to claim a tax exemption for petitioner’s minor child, despite not being the child’s custodial parent, could operate as a substitute Form 8332 (Release/Revocation of Release of Claim to Exemption for Child by

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Scott St. Amand June 15, 2020
Income Tax Issues
Tax Opinions

Nelson v. Commissioner
T.C. Memo. 2020-81

On June 10, 2020, the Tax Court issued a Memorandum Opinion in the case of Nelson v. Commissioner (T.C. Memo. 2020-81). The primary issue before the court in Nelson v. Commissioner was whether the limited partnership interests, transferred on December 31, 2008, and January 2, 2009, were fixed dollar amounts or percentage interests, which in turn affected whether the gifts were complete when transferred, which in turn affected inclusion on the petitioners’ income tax returns

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Scott St. Amand June 10, 2020
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