Income Tax Issues
Income Tax Issues

Skolnick v. Commissioner
T.C. Memo. 2021-139

On December 16, 2021, the Tax Court issued a Memorandum Opinion in the case of Skolnick v. Commissioner (T.C. Memo. 2021-139). The primary issue presented in Skolnick was whether the petitioner’s “horse activity,” undertaken through his LLC, was an activity not engaged in for profit within the meaning of IRC § 183 during 2010-2013. Held: Petitioners were just horsing around, but they had reasonable cause to avoid the accuracy-related penalties. On Horse Breeding and Miniature

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Scott St. Amand April 25, 2022
Income Tax Issues
Income Tax Issues

Safaryan v. Commissioner
T.C. Memo. 2021-138

On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held: Not so much. Background to Safaryan v. Commissioner In 2012 or 2013 the petitioner-husband purchased 10 acres of property in Newberry Springs, California. The property

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Scott St. Amand April 24, 2022
Income Tax Issues
Full Tax Court Opinions

Coggin v. Commissioner
157 T.C. No. 12

On December 8, 2021, the Tax Court issued its opinion in Coggin v. Commissioner, 157 T.C. No. 12. The primary issue presented in Coggin was whether the Tax Court lacked jurisdiction in a refund suit for years in which the District Court had previously acquired jurisdiction. Background The petitioner filed amended returns for tax years 2001 through 2009, claiming refunds for 2001 through 2007. The IRS rejected the refund requests for 2003, 2004, and 2007.

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Scott St. Amand April 20, 2022
Income Tax Issues
Income Tax Issues

Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay advance premium tax credit (APTC) payments of the PTC. Held: Yup and yeppers. Background to Knox v. Commissioner The petitioners were (and perhaps still are)

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Scott St. Amand March 30, 2022
Income Tax Issues
Income Tax Issues

Amburgey v. Commissioner
T.C. Memo. 2021-124

On November 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Amburgey v. Commissioner (T.C. Memo. 2021-124). The primary issue presented in Amburgey v. Commissioner was whether the petitioners were required to repay an advance premium tax credit, or whether requiring them to do so was unconstitutional. Held: Pay up, petitioners. Background to Amburgey v. Commissioner The petitioners, a married couple, reported an adjusted gross income of $181,183 on their joint

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Scott St. Amand November 15, 2021
Income Tax Issues
Income Tax Issues

Dodd v. Commissioner
T.C. Memo. 2021-118

On October 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Dodd v. Commissioner (T.C. Memo. 2021-118). The primary issue presented in Dodd v. Commissioner were whether the petitioner was liable for the unpaid tax related to unreported IRC § 1231 gain Holding: Indeed she was. Background to Dodd v. Commissioner During 2013, the petitioner in Dodd v. Commissioner was employed as the office manager of a law firm in Washington,

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Scott St. Amand October 25, 2021
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