Penalties Under the Code
Memorandum Opinions

Battat v. Commissioner
T.C. Memo. 2021-57

On May 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Battat v. Commissioner (T.C. Memo. 2021-57). The primary issue presented in Battat v. Commissioner was whether the IRS received prior supervisory approval of an initial determination of a penalty under IRC § 6751(b)(1). Same Issue, New Wrinkle in Battat v. Commissioner The IRC § 6751(b)(1) prior supervisory approval rule has been litigated with substantial regularity over the last year and

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Scott St. Amand May 11, 2021
Income Tax Issues
Income Tax Issues

Adler v. Commissioner
T.C. Memo. 2021-56

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Adler v. Commissioner (T.C. Memo. 2021-56). The primary issue presented in Adler v. Commissioner was whether the petitioner was entitled to deduct business expenses for 2016 and 2017 (the years in issue). Adler v. Commissioner In Short The petitioner was a consultant for an entertainment company in Los Angeles.  He incurred business-related expenses, including travel expenses, and he reported these

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Scott St. Amand May 10, 2021
Procedural Issues
Memorandum Opinions

Bailey v. Commissioner
T.C. Memo. 2021-55

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Bailey v. Commissioner (T.C. Memo. 2021-55). The primary issue presented in Bailey v. Commissioner was whether the petitioners should (or could) be relieved from the stipulation of facts that they voluntarily entered into with the IRS before trial. Background to Bailey v. Commissioner The petitioners’ personal income tax returns (and a related corporate return) were audited for a number of

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Scott St. Amand May 10, 2021
Penalties Under the Code
Memorandum Opinions

Jenkins v. Commissioner
T.C. Memo. 2021-54

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Jenkins v. Commissioner (T.C. Memo. 2021-54). The primary issues presented in Jenkins v. Commissioner was whether the IRS has proven fraud, and the amount of unreported income for the consolidated petitioners. Just a Head’s Up re: Jenkins v. Commissioner This opinion by Judge Holmes contains a “waddle” of penguins that speak in French, a forged Kerguelenois diplomatic passport, and a

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Scott St. Amand May 10, 2021
Charitable Issues

Tikar Inc. v. Commissioner
T.C. Memo. 2021-53

On May 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Tikar Inc. v. Commissioner (T.C. Memo. 2021-53). The primary issue presented in Tikar Inc. v. Commissioner was whether Tikar (organized to present exposition of African art owned by a corporation and to promote African art, generally) was operated exclusively for one or more exempt purposes pursuant to IRC § 501(c)(3). The Blessed Rains Down in Africa in Tikar Inc. v. Commissioner

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Scott St. Amand May 6, 2021
Income Tax Issues
Income Tax Issues

Berry v. Commissioner
T.C. Memo. 2021-52

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-52). The primary issues presented in Berry v. Commissioner were whether certain amounts characterized as gross receipts of a company should actually be other income to the petitioners, whether the company is entitled to deduct racecar expenses, and whether or not the petitioners substantiated COGS or a depreciation deduction under IRC § 167(a). Background to Berry

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Scott St. Amand May 5, 2021
Procedural Issues
Memorandum Opinions

Jacobs v. Commissioner
T.C. Memo. 2021-51

On May 5, 2021, the Tax Court issued a Memorandum Opinion in the case of Jacobs v. Commissioner (T.C. Memo. 2021-51). The primary issue presented in Jacobs v. Commissioner was whether the petitioner was entitled to reasonable litigation and administrative costs pursuant to IRC § 7430 and Tax Court Rule 231. A Lawyer, Scholar, and Author in Jacobs v. Commissioner The petitioner was a trial lawyer with the Department of Justice for 20 years before

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Scott St. Amand May 5, 2021
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