Income Tax Issues
Tax Opinions

Staples v. Commissioner
T.C. Memo. 2020-34

On March 11, 2020, the Tax Court issued a Memorandum Opinion in the case of Staples v. Commissioner (T.C. Memo. 2020-34). The issue presented in Staples v. Commissioner was whether petitioner is entitled to a loss deduction on account of his Federal disability annuity benefits, as reduced by the amount he received as Social Security Disability Insurance (SSDI) benefits. Background to Staples v. Commissioner The petitioner worked for the USPTO until disability forced him to

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Scott St. Amand March 11, 2020
Income Tax Issues
Tax Opinions

Grieve v. Commissioner
T.C. Memo. 2020-28

On March 2, 2020, the Tax Court issued a Memorandum Opinion in the case of Grieve v. Commissioner (T.C. Memo. 2020-28). The primary issue presented in Grieve v. Commissioner was the valuation of the petitioner’s 99.8% member interests in two LLCs, Rabbit 1, LLC and Angus MacDonald, LLC, transferred to the petitioner from a GRAT and an irrevocable trust, respectively. Background to Grieve v. Commissioner – A Three Hour Tour This is the cautionary tale

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Scott St. Amand March 2, 2020
Income Tax Issues
Tax Opinions

Keels v. Commissioner
T.C. Memo. 2020-25

On February 19, 2020, the Tax Court issued a Memorandum Opinion in the case of Keels v. Commissioner (T.C. Memo. 2020-25). The issues presented in Keels v. Commissioner were (1) whether petitioner substantiated his expenses underlying his claimed deductions by maintaining adequate records, and (2) whether, because the IRS raised the application of IRC § 409A as a new basis for disallowance of the petitioner’s deductions (which had not been raised in the notice of

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Scott St. Amand February 19, 2020
Income Tax Issues
Tax Opinions

Onyeani v. Commissioner
T.C. Memo. 2020-15

On January 16, 2020, the Tax Court issued a Memorandum Opinion in the case of Onyeani v. Commissioner (T.C. Memo. 2020-15). The issue presented in Onyeani v. Commissioner was whether the IRS appropriately issued a termination assessment against the petitioner and determined that his illegal income was taxable. Note on Onyeani v. Commissioner Hello, dear reader, I am Ogorji Timothy Wilson Onyeani, a Nigerian doctor, who has come upon a sum of money in the

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

Christensen v. Commissioner (T.C. Memo. 2020-14)

On January 15, 2020, the Tax Court issued a Memorandum Opinion in the case of Christensen v. Commissioner (T.C. Memo. 2020-14). The sole issue presented in Christensen v. Commissioner was whether employee expenses for travel to and from home and work were deductible under IRC § 162(a). Deductibility of Expenses in General as explained by Christensen v. Commissioner Because deductions are a “matter of legislative grace,” taxpayers bear the burden of establishing their entitlement thereto.

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

Aviles v. Commissioner
T.C. Memo. 2020-12

On January 14, 2020, the Tax Court issued a Memorandum Opinion in the case of Aviles v. Commissioner (T.C. Memo. 2020-12). The issue presented in Aviles v. Commissioner was whether the Tax Court should revisit its holding in Giamelli v. Commissioner, 129 T.C. 107 (2007), thereby permitting a petitioner, who failed to challenge his underlying tax liability at a CDP hearing, to raise the challenge for the first time in Tax Court. Challenging Underlying Tax

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Scott St. Amand January 14, 2020
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