Income Tax Issues
Income Tax Issues

Silver v. Commissioner (T.C. Memo. 2021-98)

On August 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Silver v. Commissioner (T.C. Memo. 2021-98). The primary issue presented in Silver v. Commissioner was whether the petitioner’s arguments were frivolous, and if so whether the imposition of a penalty for bringing a frivolous or groundless position was warranted. Background to Silver v. Commissioner The petitioner, Mr. Silver, received $28,155 in wages and $5,000 as other income in tax year

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Scott St. Amand September 28, 2021
Income Tax Issues
Income Tax Issues

Today’s Health Care II LLC v. Commissioner
T.C. Memo. 2021-96

On August 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Today’s Health Care II LLC v. Commissioner (T.C. Memo. 2021-96). The primary issue presented in Today’s Health Care II LLC v. Commissioner was whether IRC § 280E (Expenditures in Connection with the Illegal Sale of Drugs) violated the Eighth or Sixteenth Amendments to the Constitution. Held: Not today, hippie. Note: Even the initials of the company (T.H.C.) are pot-induced. Kudos, stoners.

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Scott St. Amand September 26, 2021
Income Tax Issues
Income Tax Issues

Vennes v. Commissioner
T.C. Memo. 2021-93

On July 20, 2021, the Tax Court issued a Memorandum Opinion in the case of Vennes v. Commissioner (T.C. Memo. 2021-93). The primary issues presented in Vennes v. Commissioner were whether the petitioner was entitled to passthrough theft loss deductions for 2008, and whether the petitioner was liable for the accuracy‑related penalty pursuant to IRC § 6662(a). The Petitioner’s Checkered Past in Vennes v. Commissioner In 1990, the petitioner completed a prison sentence for money

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Scott St. Amand September 2, 2021
Income Tax Issues
Income Tax Issues

Hussey v. Commissioner
156 T.C. No. 12

On June 24, 2021, the Tax Court issued its opinion in Hussey v. Commissioner (156 T.C. No. 12). The primary issues presented in Hussey v. Commissioner were whether the petitioner was required to reduce his bases in disposed depreciable real properties immediately before sales of those properties in year of discharge of qualified real property business indebtedness (QRPBI), rather than in subsequent year; whether the taxpayer had discharge of indebtedness income; and whether the taxpayer

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Scott St. Amand August 31, 2021
Income Tax Issues
Income Tax Issues

Ryder & Associates Inc. v. Commissioner
T.C. Memo. 2021-88

On July 14, 2021, the Tax Court issued a Memorandum Opinion in the case of Ryder & Associates Inc. v. Commissioner (T.C. Memo. 2021-88). The primary issues presented in Ryder & Associates Inc. v. Commissioner were whether the petitioners received unreported gross receipts from their company, and whether the petitioners had significant unreported dividend income. Author’s Note on Ryder & Associates v. Commissioner As I mentioned earlier this year, I have never seen it bode well for

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Scott St. Amand July 29, 2021
Income Tax Issues
Income Tax Issues

Blossom Day Care Centers Inc. v. Commissioner
T.C. Memo. 2021-87

On July 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Blossom Day Care Centers Inc. v. Commissioner (T.C. Memo. 2021-87). The primary issues presented in Blossom Day Care Centers Inc. v. Commissioner were whether the petitioner was failed to report capital gain and gross receipts, whether the petitioner is entitled to certain deductions, whether the petitioner is entitled to Indian tax credits, and most importantly, whether the petitioner is liable for

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Scott St. Amand July 29, 2021
Income Tax Issues
Income Tax Issues

Blossom Day Care Centers Inc. v. Commissioner
T.C. Memo. 2021-86

On July 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Blossom Day Care Centers Inc. v. Commissioner (T.C. Memo. 2021-86). The issues presented in Blossom Day Care Centers Inc. v. Commissioner were whether: (1) the day care’s corporate officers should be legally classified as employees of petitioner such that petitioner is liable for employment tax (FICA) and unemployment tax (FUTA); (2) petitioner was liable for FICA and FUTA taxes; (3) petitioner

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Scott St. Amand July 28, 2021
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