Procedural Issues
Memorandum Opinions

Lufkin v. Commissioner
T.C. Memo. 2021-71

On June 8, 2021, the Tax Court issued a Memorandum Opinion in the case of Lufkin v. Commissioner (T.C. Memo. 2021-71). The primary issue presented in Lufkin v. Commissioner was whether the pro se petitioner was liable for certain Form 941 liabilities. Background to Lufkin v. Commissioner The IRS assessed the Form 941 liabilities, which arose in connection with the petitioner’s law practice, for the periods at issue in December 1998 and June 1999, respectively. After the

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Scott St. Amand June 21, 2021
Procedural Issues
Memorandum Opinions

Verghese v. Commissioner
T.C. Memo. 2021-70

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Verghese v. Commissioner (T.C. Memo. 2021-70). The primary issues presented in Verghese v. Commissioner were (1) whether, under IRC § 6404(a) the petitioners are entitled to abatement on the basis of principles of fairness, and (2) whether under IRC § 6404(e) the IRS engaged in ministerial or managerial acts that constituted unreasonable delay for which the petitioners’ abatement request should

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Scott St. Amand June 21, 2021
Income Tax Issues
Income Tax Issues

Holliday v. Commissioner
T.C. Memo. 2021-69

On June 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Holliday v. Commissioner (T.C. Memo. 2021-69). The primary issue presented in Holliday v. Commissioner was whether settlement proceeds petitioner received in 2014 constitute taxable income. Background to Holliday v. Commissioner Two lawsuits are central to this case. The first is petitioner’s divorce proceeding, in which she was represented by J. Beverly and his law firm (divorce attorney and malpractice defendants,

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Scott St. Amand June 21, 2021
Business Related Issues
Business Related Issues

ES NPA HOLDING LLC v. Commissioner
T.C. Memo. 2021-68

On June 3, 2021, the Tax Court issued a Memorandum Opinion in the case of ES NPA HOLDING LLC v. Commissioner (T.C. Memo. 2021-68). The primary issue presented in ES NPA HOLDING LLC v. Commissioner was whether the adjustment to ES NPA’s 2011 ordinary income originates at the level of another limited liability company, IDS, in which the petitioner held an interest, which is to say that the adjustment is a partnership item of IDS and

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Scott St. Amand June 21, 2021
Business Related Issues
Business Related Issues

New Capital Fire Inc. v. Commissioner
T.C. Memo. 2021-67

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of New Capital Fire Inc. v. Commissioner (T.C. Memo. 2021-67). The primary issue presented in New Capital Fire Inc. v. Commissioner was whether the petitioner is barred under the doctrine of equitable estoppel from changing its reporting of its bases in certain assets that the petitioner acquired in the merger because the statute of limitations bars assessment. Dancing the Merger Two Step

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Scott St. Amand June 21, 2021
Income Tax Issues
Income Tax Issues

Torres v. Commissioner
T.C. Memo. 2021-66

On June 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Torres v. Commissioner (T.C. Memo. 2021-66). The issues presented in Torres v. Commissioner were whether the petitioner was entitled to reduce his flowthrough income from his wholly owned S corporation for a theft loss deduction pursuant to IRC § 165. Background to Torres v. Commissioner As of 2016, the petitioner was illiterate—whether because of an illness or because he didn’t ascribe

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Scott St. Amand June 21, 2021
Income Tax Issues
Income Tax Issues

Grossman v. Commissioner
T.C. Memo. 2021-65

On May 27, 2021, the Tax Court issued a Memorandum Opinion in the case of Grossman v. Commissioner (T.C. Memo. 2021-65). The primary issue presented in Grossman v. Commissioner was whether state law determines a taxpayer’s marital status at death for purposes of the marital deduction under IRC § 2056(a). The Saga of Semone in Grossman v. Commissioner All Semone Grossman wanted was to find a nice Jewish girl to settle down with. He had survived

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Scott St. Amand June 21, 2021
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