International
International Issues

Kaebel v. Commissioner (T.C. Memo. 2021-109)

On September 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Kaebel v. Commissioner (T.C. Memo. 2021-109). The primary issues presented in Kaebel were (a) whether the petitioner was precluded from arguing that the IRS did not send him deficiency notices; (b) whether the IRS erred in certifying that the petitioner had seriously delinquent tax debt; and (c) whether the petitioner should be sanctioned for advancing the groundless argument that the

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International
International Issues

Garcia v. Commissioner (157 T.C. No. 1)

On July 19, 2021, the Tax Court issued its opinion in Garcia v. Commissioner, 157 T.C. No. 1. The primary issues presented in Garcia were whether the petition to reverse the certification of a seriously delinquent tax debt was mooted by the actual reversal and whether the Tax Court had jurisdiction in a passport certification case to determine whether the rejection of a collection alternative was in error. Background of Certification Statute IRC § 7345,

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International
International Issues

Landrau v. Commissioner (T.C. Memo. 2021-72)

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Landrau v. Commissioner (T.C. Memo. 2021-72). The primary issue presented in Landrau was whether the IRS correctly computed their allowable foreign tax credit for 2012. Background During 2014 petitioner-husband received wages of $74,680 for services performed in Puerto Rico for the U.S. Air Force. Petitioner-wife received a pension distribution of $10,380 and U.S. Social Security benefits of $14,698. The petitioners

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International
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 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 The petitioner is a U.K. corporation

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Procedural Issues
Tax Opinions

Flume v. Commissioner (T.C. Memo. 2020-80)

On June 9, 2020, the Tax Court issued a Memorandum Opinion in the case of Flume v. Commissioner (T.C. Memo. 2020-80). The primary issue before the court in Flume was whether the petitioners had subpart F income.

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International
Tax Opinions

Whirlpool Financial Corporation v. Commissioner (154 T.C. No. 9)

On May 5, 2020, the Tax Court issued its opinion in Whirlpool Financial Services v. Commissioner, 154 T.C. No. 9. The issue presented in Whirlpool Financial was whether the income earned by the petitioner’s Luxembourg controlled foreign corporation (CFC) from sales of appliances to the petitioner and the petitioner’s Mexican CFC constituted foreign base company sales income (FBCSI) under IRC § 954(d) and, as such, was taxable to the petitioner as subpart F income under

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International
Tax Opinions

Adams Challenge (U.K.) Limited v. Commissioner (154 T.C. No. 3)

On January 8, 2020, the Tax Court issued its opinion in Adams Challenge (U.K.) Limited v. Commissioner, 154 T.C. No. 3. The issue presented in Adams Challenge (U.K.) was whether a United Kingdom private limited liability company, whose vessel was leased to a U.S. company operating on portions of the U.S. Outer Continental Shelf (OCS) received income effectively connected with a U.S. trade or business pursuant to IRC § 882(a)(1), thereby giving rise to a

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McCrory v. Commissioner (T.C. Memo. 2021-116)

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of McCrory v. Commissioner (T.C. Memo. 2021-116). The primary issue presented in McCrory was whether the IRS Whistleblower Office’s rejections of the petitioner’s claims were unsupported by the administrative record and were arbitrary, capricious, an abuse

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Gregory v. Commissioner (T.C. Memo. 2021-115)

On September 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Gregory v. Commissioner (T.C. Memo. 2021-115). The primary issue presented in Gregory was whether the claimed deductions permitted under IRC § 183(b) for activities not engaged in for profit are not subject to the 2%

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A Primer on Employment Tax Withholding

When the IRS is involved, monetary transactions are never as simple as they appear on the surface. The late, great comedian Mitch Hedberg once told a story about being given a receipt after buying a doughnut. I bought a doughnut, and they gave me a receipt for the doughnut. I

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Clark v. Commissioner (T.C. Memo. 2021-114)

On September 28, 2021, the Tax Court issued a Memorandum Opinion in the case of Clark v. Commissioner (T.C. Memo. 2021-114). The primary issue presented in Clark was whether the petitioner fraudulently underreported his income. Held:  Oh, dear God.  The fraud! The Tax Court’s Summary of the Issue in Clark

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Whistleblower 14377-16W v. Commissioner (T.C. Memo. 2021-113)

On September 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 14377-16W v. Commissioner (T.C. Memo. 2021-113). The primary issues presented in Whistleblower 14377-16W were whether the whistleblower could proceed anonymously, and whether the WBO abused its discretion in denying the whistleblower-petitioner an award. Held:

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Brown v. Commissioner (T.C. Memo. 2021-112)

On September 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Brown v. Commissioner (T.C. Memo. 2021-112). The sole issue presented in Brown was whether the Tax Court has jurisdiction to order the refund of a TIPRA payment. What is a TIPRA Payment? The Tax Increase

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