Procedural Issues
Memorandum Opinions

American Limousines Inc. v. Commissioner
T.C. Memo. 2021-36

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of American Limousines Inc. v. Commissioner (T.C. Memo. 2021-36). The primary issues presented in American Limousines Inc. v. Commissioner were whether the IRS abused its discretion in rejecting an installment agreement (that the petitioner could not fund) and whether the IRS abused its discretion in refusing to classify the petitioner’s account as currently not collectible. Background to American Limousines Inc. v. Commissioner

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Scott St. Amand March 24, 2021
Procedural Issues
Memorandum Opinions

Siebert v. Commissioner
T.C. Memo. 2021-34

On March 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Siebert v. Commissioner (T.C. Memo. 2021-34). The primary issue presented in Siebert v. Commissioner was whether the settlement officer abused her discretion in sustaining the proposed collection action A Note on Petitioner’s Appeal in Siebert v. Commissioner I am a big believer in karma.  The petitioners may or may not have had this decision coming.  Here’s a brief summary of why

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Scott St. Amand March 15, 2021
Income Tax Issues
Income Tax Issues

Ward v. Commissioner
T.C. Memo. 2021-32

On March 15, 2021, the Tax Court issued a Memorandum Opinion in the case of Ward v. Commissioner (T.C. Memo. 2021-32). The primary issues presented in Ward were whether the petitioner properly reported income, whether the petitioner was entitled to the insolvency exception to IRC § 108 to avoid income inclusion for discharge of indebtedness income, and whether the petitioner was just completely full of shit. She was. Personal Note I sympathize with the petitioner

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Scott St. Amand March 15, 2021
Income Tax Issues
Income Tax Issues

Martin v. Commissioner
T.C. Memo. 2021-35

On March 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Martin v. Commissioner (T.C. Memo. 2021-35). The primary issues presented in Martin v. Commissioner were whether the IRS abused its discretion in disallowing substantial (old and large) deductions and whether the petitioners were liable for penalties for filing (very) late and for being (very) negligent and for (very) substantially understating their liabilities. Background to NOLs in Martin v. Commissioner The

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Scott St. Amand March 14, 2021
Penalties Under the Code
Income Tax Issues

Harriss v. Commissioner
T.C. Memo. 2021-31

On March 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Harriss v. Commissioner (T.C. Memo. 2021-31). The primary issues presented in Harriss v. Commissioner were whether the notices of deficiency issued to the petitioners were valid and whether the petitioner is liable under IRC § 72(t) for the early withdrawal penalty. Shenanigans in Harriss v. Commissioner The petitioner was paid, on average, $150,000 in 2012, 2013, and 2014.  Forms 1099

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Scott St. Amand March 11, 2021
Business Related Issues
Business Related Issues

Caylor Land & Development v. Commissioner
T.C. Memo. 2021-30

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Caylor Land & Development v. Commissioner (T.C. Memo. 2021-30). The primary issues presented in Caylor Land & Development v. Commissioner were whether consulting payments made between the petitioner and its microcaptive insurance company were ordinary and necessary business expenses or insurance expenses. Brief Background (to Lay a Foundation for Judge Holmes’ Puns) in Caylor Land & Development v. Commissioner The

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Scott St. Amand March 10, 2021
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