International Issues
International Issues

Aptargroup Inc. v. Commissioner
158 T.C. No. 4

On March 16, 2022, the Tax Court issued the full opinion in Aptargroup Inc. v. Commissioner (158 T.C. No. 4). The primary issue presented in Aptargroup Inc. v. Commissioner was whether the taxpayer was required to characterize stock in controlled foreign corporation using gross income method. Held: Yes, indeed it was. Aptargroup Inc. v. Commissioner in a Nutshell Aptargroup Inc. owns stock in a controlled foreign corporation (CFC). The CFC apportioned interest expenses under the

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Scott St. Amand June 10, 2022
International Issues
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 v. Commissioner 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

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Scott St. Amand October 8, 2021
International Issues
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 v. Commissioner 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 in Garcia

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Scott St. Amand August 31, 2021
International Issues
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 to Landrau v. Commissioner 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

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Scott St. Amand June 21, 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
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 v. Commissioner was whether the petitioners had subpart F income. Burden of Proof in Unreported Income Cases as in Flume v. Commissioner Generally, the IRS’s determinations regarding income set forth in a notice of deficiency are presumed correct and the taxpayer bears the burden of proving

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Scott St. Amand June 9, 2020
International Issues
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 Corporation v. Commissioner (154 T.C. No. 9). The issue presented in Whirlpool Financial Corporation v. Commissioner 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

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Scott St. Amand May 5, 2020
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