Business Related Issues
Business Related Issues

Goldberg v. Commissioner
T.C. Memo. 2021-119

On October 19, 2021, the Tax Court issued a Memorandum Opinion in the case of Goldberg v. Commissioner (T.C. Memo. 2021-119). The primary issue presented in Goldberg v. Commissioner was whether Mr. Goldberg is prohibited from now challenging his underlying tax liabilities because of his failure to challenge an earlier Notice of Federal Tax Lien Filing and Your Right to a Hearing under IRC § 6320 or because of his nonparticipation in an even earlier

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Scott St. Amand November 3, 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
Penalties Under the Code
Memorandum Opinions

Crim v. Commissioner
T.C. Memo. 2021-117

On October 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Crim v. Commissioner (T.C. Memo. 2021-117). The primary issue presented in Crim v. Commissioner was whether the penalties assessed against the petitioner for promotion of abusive tax shelters under IRC § 6700(a) were assessed the period of limitations on assessment had expired. Author’s Note: If you read nothing else, I beg you to read the Post Script, where I describe the

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Scott St. Amand October 22, 2021
Procedural Issues
Memorandum Opinions

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 v. Commissioner 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 of discretion, or otherwise not in accordance with the law. Background to Whistleblower Claims in McCrory v. Commissioner The petitioner submitted six Forms 211

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Scott St. Amand October 20, 2021
Income Tax Issues
Income Tax Issues

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 v. Commissioner was whether the claimed deductions permitted under IRC § 183(b) for activities not engaged in for profit are not subject to the 2% floor on miscellaneous itemized deductions set forth in IRC § 67(a). Background to Gregory v. Comissioner During the years at issue, 2014 and 2015, the

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Scott St. Amand October 18, 2021
Penalties Under the Code
Memorandum Opinions

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 v. Commissioner  was whether the petitioner fraudulently underreported his income. Held:  Oh, dear God.  The fraud! The Tax Court’s Summary of the Issue in Clark v. Commissioner And I quote: In 2011 through 2014, the years at issue, Robert S. Clark owned an auto body shop, rental properties,

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Scott St. Amand October 14, 2021
Procedural Issues
Memorandum Opinions

Whistleblower 1437716W v. Commissioner
T.C. Memo. 2021-113

On September 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Whistleblower 1437716W v. Commissioner (T.C. Memo. 2021-113). The primary issues presented in Whistleblower 1437716W v. Commissioner were whether the whistleblower could proceed anonymously, and whether the WBO abused its discretion in denying the whistleblower-petitioner an award. Held: Nope on both counts. Background to “Old 77” Whistleblower and Whistleblower 1437716W Peter J. Reilly, a Forbes tax contributor, nicknamed the whistleblower in Whistleblower 1437716W

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Scott St. Amand October 12, 2021
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