Penalties Under the Code
Memorandum Opinions

Flynn v. Commissioner
T.C. Memo. 2021-43

On April 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Flynn v. Commissioner (T.C. Memo. 2021-43). The primary issue presented in Flynn v. Commissioner was whether the petitioner’s failure to file returns for 1999, 2000, and 2001 was fraudulent. Tax Court’s Holding in Flynn v. Commissioner:   It’s a Damn Conspiracy (No, Really, It Is) The petitioner took part in a bit of a criminal conspiracy, which bilked 577 suckers

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Scott St. Amand April 13, 2021
Business Related Issues
Business Related Issues

Berry v. Commissioner
T.C. Memo. 2021-42

On April 7, 2021, the Tax Court issued a Memorandum Opinion in the case of Berry v. Commissioner (T.C. Memo. 2021-42). The primary issues presented in Berry v. Commissioner were whether the petitioners S corporation underreported its income, whether the petitioners’ S corporation is entitled to certain claimed deductions, whether the petitioners are entitled to certain claimed deductions, and whether the petitioners are liable for accuracy-related penalties under IRC § 6662. Background to Berry v.

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Scott St. Amand April 7, 2021
Business Related Issues
Business Related Issues

Olsen v. Commissioner
T.C. Memo. 2021-41

On April 6, 2021, the Tax Court issued a Memorandum Opinion in the case of Olsen v. Commissioner (T.C. Memo. 2021-41). The primary issues presented in Olsen v. Commissioner were whether the petitioners were entitled to depreciation deductions reported on Schedules C (Profit or Loss from Business) and whether they were entitled to energy tax credits reported on Forms 3800 (General Business Credit) for deductions and credits related to a solar energy tax shelter.  Held:

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Scott St. Amand April 6, 2021
Penalties Under the Code
Memorandum Opinions

Walton v. Commissioner
T.C. Memo. 2021-40

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background to Walton v. Commissioner The petitioner was a New Yorker,[1] who failed to report $170,000 in nonemployee compensation in 2015. Strike one and two. The petitioner was terminated from her

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Scott St. Amand March 30, 2021
Income Tax Issues
Income Tax Issues

Max v. Commissioner
T.C. Memo. 2021-37

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Max v. Commissioner (T.C. Memo. 2021-37). The primary issue presented in Max was whether drawing fashion sketches qualify as “qualified research” under IRC § 41. General Observations in Max v. Commissioner Who knew Judge Buch was such a fashionista? If you don’t believe me, read the first 21 pages of the opinion.  The editor of Teen Vogue better watch out.  Judge

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Scott St. Amand March 29, 2021
Procedural Issues
Memorandum Opinions

Crandall v. Commissioner
T.C. Memo. 2021-39

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Crandall v. Commissioner (T.C. Memo. 2021-39). The primary issue presented in Crandall v. Commissioner was whether the parties’ closing agreement precluded the determined deficiency and penalty. Background to Determination in Crandall v. Commissioner During taxable years 2003 through 2011 the petitioners received foreign-source pension income, interest income, and ordinary dividends. For each of those years they paid Italian income tax. 

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Scott St. Amand March 29, 2021
Income Tax Issues
Income Tax Issues

Purple Heart Patient Center Inc. v. Commissioner
T.C. Memo. 2021-38

On March 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Purple Heart Patient Center Inc. v. Commissioner (T.C. Memo. 2021-38). The primary issues presented in Purple Heart Patient Center Inc. v. Commissioner were whether the petitioner (1) was entitled to offset its gross receipts with any cost of goods sold (COGS), (2) underreported its gross income, and (3) is liable for the accuracy-related penalty pursuant to IRC § 6662(a). Background to Purple

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Scott St. Amand March 29, 2021
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