Income Tax Issues
Tax Opinions

Gallegos v. Commissioner
T.C. Memo. 2021-25

On March 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gallegos v. Commissioner (T.C. Memo. 2021-25). The primary issue presented in Gallegos v. Commissioner was whether the team roping expenses the petitioner claimed on his Schedule C as business losses were business or personal in nature. Giddy-up, ya’ll… Setting the Stage for Gallegos v. Commissioner First, this is a Judge Holmes opinion, so you know it’s going to be gold.

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Scott St. Amand March 2, 2021
Income Tax Issues
Tax Opinions

Anikeev v. Commissioner
T.C. Memo. 2021-23

On February 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Anikeev v. Commissioner (T.C. Memo. 2021-23). The primary issue presented in Anikeev v. Commissioner was whether the “rewards” earned from the purchase of gift cards…a lot of gift cards…were income. Background to Anikeev v. Commissioner The petitioners were crafty Russians, who gamed the credit card reward system.  They joined a credit card rewards program and proceeded to purchase their credit

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Scott St. Amand February 23, 2021
Income Tax Issues
Tax Opinions

Desert Organic Solutions v. Commissioner
T.C. Memo. 2021-22

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Desert Organic Solutions v. Commissioner (T.C. Memo. 2021-22). The primary issue presented in Desert Organic Solutions v. Commissioner was whether the petitioner, a marijuana-based California business, was liable for a deficiency on the grounds that its activities were illegal under federal law. Note on My Tax Court Hero This is the first of Judge Holmes’ decisions with which I was a

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Scott St. Amand February 22, 2021
Income Tax Issues
Tax Opinions

Rogers v. Commissioner
T.C. Memo. 2021-20

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Rogers v. Commissioner (T.C. Memo. 2021-20). The primary issue presented in Rogers v. Commissioner was whether the petitioner was eligible for innocent spouse relief under IRC § 6015(b), (c), or (f). The Wisconsin Tent & Pony Show in Rogers v. Commissioner The petitioner and her erstwhile husband owned the top[1] tent rental company in Madison, Wisconsin.  The petitioner also solely

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Scott St. Amand February 22, 2021
Income Tax Issues
Tax Opinions

Blum v. Commissioner
T.C. Memo. 2021-18

On February 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Blum v. Commissioner (T.C. Memo. 2021-18). The primary issue presented in Blum v. Commissioner was whether the petitioner was entitled to exclude from her gross income the $125,000 settlement payment (from a suit against former attorneys who bungled a personal injury lawsuit on petitioner’s behalf) as damages received “on account of personal physical injuries or physical sickness” under IRC §

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Scott St. Amand February 18, 2021
International Issues
Full Tax Court Opinions

Adams Challenge UK Limited v. Commissioner
156 T.C. No. 3

On January 25, 2021, the Tax Court issued its opinion in Adams Challenge UK Limited v. Commissioner (156 T.C. No. 3). The underlying issue presented in Adams Challenge UK Limited v. Commissioner was whether the IRS erred in disallowing the petitioner’s deductions and credits and whether the IRS’s action violated the business profits and the nondiscrimination articles of the bilateral income tax treaty between the United States and the U.K. Background to Adams Challenge UK Limited

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Scott St. Amand January 25, 2021
Income Tax Issues
Full Tax Court Opinions

San Jose Wellness v. Commissioner
156 T.C. No. 4

On February 17, 2021, the Tax Court issued its opinion in San Jose Wellness v. Commissioner (156 T.C. No. 4). The underlying issue presented in San Jose Wellness v. Commissioner was whether the petitioner, a marijuana dispensary, was prohibited from claiming deductions for depreciation and charitable contributions under IRC § 280E. Background to San Jose Wellness v. Commissioner The petitioner operated a medical marijuana dispensary pursuant to California law from 2010 to 2015. It sold marijuana

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Scott St. Amand January 17, 2021
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