Income Tax Issues
Tax Opinions

Etoty v. Commissioner
T.C. Memo. 2020-49

On April 20, 2020, the Tax Court issued a Memorandum Opinion in the case of Etoty v. Commissioner (T.C. Memo. 2020-49). The issue before the court in Etoty v. Commissioner was whether the levy on the petitioner’s New York State tax refund should not [sic] be sustained. A Lesson in Etoty v. Commissioner to Judge Lauber on When “Less is More” Should be Ignored Petitioner filed a timely Federal income tax return for 2008. Because

Read More »
Scott St. Amand April 20, 2020
Income Tax Issues
Tax Opinions

Williams v. Commissioner
T.C. Memo. 2020-48

On April 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Williams v. Commissioner (T.C. Memo. 2020-48). The primary issue before the court in Williams v. Commissioner was whether the petitioners were entitled to deductions on Schedule C (Profit or Loss from Business) for the expenses of the petitioner-husband’s new business venture as he grew it and prior to the business’ actual operation. The Basic Nature of Deductions in Williams v.

Read More »
Scott St. Amand April 14, 2020
Income Tax Issues
Tax Opinions

Hakkak v. Commissioner
T.C. Memo. 2020-46

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Hakkak v. Commissioner (T.C. Memo. 2020-45). The issue properly before the court in Hakkak v. Commissioner was whether petitioners are entitled to treat as nonpassive certain rental real estate losses they previously treated as passive under IRC § 469 on their Schedules E (Supplemental Income and Loss) for the years at issue. The 2011 and 2012 Returns in Hakkak v.

Read More »
Scott St. Amand April 13, 2020
Income Tax Issues
Tax Opinions

Pinkston v. Commissioner
T.C. Memo. 2020-44

On April 13, 2020, the Tax Court issued a Memorandum Opinion in the case of Pinkston v. Commissioner (T.C. Memo. 2020-44). The issue properly before the court in Pinkston v. Commissioner was whether the IRS appropriately “recaptured” depreciation deductions that the petitioners claimed on rental properties prior to the years at issue, as to which years the limitation period had expired. Background to Pinkston v. Commissioner In 2003 and 2010, the petitioners acquired two rental

Read More »
Scott St. Amand April 13, 2020
Income Tax Issues
Tax Opinions

Littlejohn v. Commissioner (T.C. Memo. 2020-42)

On April 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Littlejohn v. Commissioner (T.C. Memo. 2020-42). The issues properly before the court in Littlejohn v. Commissioner were whether (1) the petitioners are entitled to certain rental real estate deductions for the tax years at issue; (2) whether the petitioners are entitled to theft loss deductions for their tax years 2010 and 2013; and (3) whether the petitioners are liable for

Read More »
Scott St. Amand April 9, 2020
Income Tax Issues
Tax Opinions

Estate of Moore v. Commissioner
T.C. Memo. 2020-40

On April 7, 2020, the Tax Court issued a Memorandum Opinion in the case of Estate of Moore v. Commissioner (T.C. Memo. 2020-40). The general issues before the court in Estate of Moore v. Commissioner were (1) whether the petitioner’s complex estate plan actually reduced the size of his taxable estate and (2) whether the petitioner’s estate planning resulted in unintended taxable gifts. The Tax Court answers these questions through a most thorough analysis of IRC

Read More »
Scott St. Amand April 7, 2020
Income Tax Issues
Tax Opinions

Biddle v. Commissioner
T.C. Memo. 2020-39

On April 6, 2020, the Tax Court issued a Memorandum Opinion in the case of Biddle v. Commissioner (T.C. Memo. 2020-39). The issue before the court in Biddle v. Commissioner was whether the petitioner’s payments to his former spouse, which, under the terms of a divorce decree, ended at his youngest child’s 18th birthday, were deductible alimony payments under IRC § 215 or whether the contingency related to his children transformed the “alimony” into nondeductible

Read More »
Scott St. Amand April 6, 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

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