Income Tax Issues
Tax Opinions

Johnson v. Commissioner
T.C. Memo. 2020-79

On June 8, 2020, the Tax Court issued a Memorandum Opinion in the case of Johnson v. Commissioner (T.C. Memo. 2020-79). The issues before the court in Johnson v. Commissioner were (1) whether the petitioner is entitled to deduct certain expenses on his Schedules F (Profit or Loss from Farming) for the years in issue; and (2) the valuation of a conservation easement. Driving Between Two Places of Business Deductible (if One is Not Your

Read More »
Scott St. Amand June 8, 2020
Income Tax Issues
Tax Opinions

Sage v. Commissioner (154 T.C. No. 12)

On June 2, 2020, the Tax Court issued its opinion in Sage v. Commissioner (154 T.C. No. 12). The issue presented in Sage v. Commissioner was whether the petitioner, who wholly owned an S corporation and LLC, which in turn owned (indirectly) and transferred three encumbered properties to separate liquidating trusts that disposed of the parcels with the profits going to pay off the liabilities of the S corporation and LLC, was the owner/grantor of

Read More »
Scott St. Amand June 2, 2020
Income Tax Issues
Tax Opinions

Kroner v. Commissioner
T.C. Memo. 2020-73

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Kroner v. Commissioner (T.C. Memo. 2020-73). The issues before the court in Kroner v. Commissioner were (1) whether transfers of funds to petitioner during the years at issue constitute gifts that petitioner properly excluded from gross income under IRC § 102 and (2) whether petitioner is liable for accuracy-related penalties under IRC § 6662. How Many Kroners does it Take

Read More »
Scott St. Amand June 1, 2020
Income Tax Issues
Tax Opinions

Estate of Bolles v. Commissioner
T.C. Memo. 2020-71

On June 1, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Bolles v. Commissioner (T.C. Memo. 2020-71). The sole issue before the court in Estate of Bolles v. Commissioner was whether the transfers from the decedent, Mary Bolles, to her son Peter, which transfers aggregated over $1m, should be treated as loans or gifts. According to the Tax Court, “Each side sees the answer as totally one way. We disagree

Read More »
Scott St. Amand June 1, 2020
Income Tax Issues
Tax Opinions

Engle v. Commissioner
T.C. Memo. 2020-69

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Engle v. Commissioner (T.C. Memo. 2020-69). The sole issue before the court in Engle v. Commissioner was whether the criminal restitution order in this case falls within the scope of Firearms Excise Tax Improvement Act of 2010 (FETIA), Pub. L. No. 111-237, sec. 3, 124 Stat. at 2497, and therefore under the guidance of Klein v. Commissioner, 149 T.C. 341, 350

Read More »
Scott St. Amand May 28, 2020
Income Tax Issues
Tax Opinions

Novoselsky v. Commissioner
T.C. Memo. 2020-68

On May 28, 2020, the Tax Court issued a Memorandum Opinion in the case of Novoselsky v. Commissioner (T.C. Memo. 2020-68). The issues before the court in Novoselsky v. Commissioner were (1) whether (1) the litigation advance support payments were loans or gross income, and whether petitioners were liable for accuracy-related penalties. Background Facts to Novoselsky v. Commissioner During 2009 and 2011, the petitioner-husband (PH) practiced law with a focus on class action litigation. In

Read More »
Scott St. Amand May 28, 2020
Income Tax Issues
Income Tax Issues

Thoma v. Commissioner
T.C. Memo. 2020-67

On May 27, 2020, the Tax Court issued a Memorandum Opinion in the case of Thoma v. Commissioner (T.C. Memo. 2020-67). Although there are a number of sub-issues related to whether the petitioner-husband (PH) was an employee or independent contractor, including deductibility of medical and business expenses, the core issue in Thoma v. Commissioner boils down to the age old question of whether PH was an employee or independent contractor of an accounting firm. Brief

Read More »
Scott St. Amand May 27, 2020
Facebook
Twitter
LinkedIn
Pocket
Email
Print

Most popular posts:

Redefining Your Financial Outlook for Greater Life Success
Guest Post

Redefining Your Financial Outlook for Greater Life Success Guest Writer:  Michael Longsdon of ElderFreedom.net* It’s a powerful realization that our financial success is deeply intertwined with our money mindset. This article will guide you through the steps to rewire your perception of money and to redefine your financial outlook, opening

Read More »
Scott St. Amand November 28, 2023

Can an Estate’s Creditor Compel a Florida Personal Representative to Produce an Estate Tax Return in a Probate Proceeding?

In this article, we examine whether an estate’s creditor may compel a Florida personal representative to produce an estate tax return in a probate proceeding. On Hilda’s Passing & Packers’ Tickets When your Great-Aunt Hilda died, Uncle Bill was appointed as her co-personal representative along with Hilda’s long-time paramour, Wilhelm

Read More »
Scott St. Amand October 16, 2023

Ultimate Guide to Managing Business Finances for Entrepreneurs
Guest Post

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

Read More »
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

Read More »
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;

Read More »
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

Read More »
Scott St. Amand November 22, 2022