Penalties Under the Code
Memorandum Opinions

Smith v. Commissioner
T.C. Memo. 2021-29

On March 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Smith v. Commissioner (T.C. Memo. 2021-29). The primary issues presented in Smith v. Commissioner were whether a photocopy of an original purported return, for which the IRS has no record and on which the petitioner expects the IRS to act in making a refund, purports to be a return of income tax, and whether the petitioner was liable for the

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Scott St. Amand March 10, 2021
Penalties Under the Code
Tax Opinions

Mathews v. Commissioner
T.C. Memo. 2021-28

On March 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Mathews v. Commissioner (T.C. Memo. 2021-28). The primary issue presented in Mathews was whether the petitioner was entitled to car and truck expenses which were incurred driving from his residence to the location of his employer, a trucking company. General Rule in Mathews v. Commissioner As a general rule, expenses for traveling between one’s home and one’s place of business

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Scott St. Amand March 9, 2021
Penalties Under the Code
Tax Opinions

Chiarelli v. Commissioner
T.C. Memo. 2021-27

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Chiarelli v. Commissioner (T.C. Memo. 2021-27). The primary issues presented in Chiarelli v. Commissioner were whether the petitioner was entitled to noncash charitable contribution deductions for the years at issue and whether the petitioner was liable for the IRC § 6662(a) accuracy-related penalties for 2012 and 2013. Incomplete Form 8283 in Chiarelli v. Commissioner The petitioner inherited valuable property from

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Scott St. Amand March 3, 2021
Tax Opinions

Pankratz v. Commissioner
T.C. Memo. 2021-26

On March 3, 2021, the Tax Court issued a Memorandum Opinion in the case of Pankratz v. Commissioner (T.C. Memo. 2021-26). The primary issue presented in Pankratz v. Commissioner was whether the failure to attach appraisals can be due to reasonable cause when a taxpayer admits that he did not review his tax returns before filing. Introductory Notes: I cannot say for sure whether the return preparers were actually the fire chief and the village

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Scott St. Amand March 3, 2021
Income Tax Issues
Tax Opinions

Gallegos v. Commissioner
T.C. Memo. 2021-25

On March 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Gallegos v. Commissioner (T.C. Memo. 2021-25). The primary issue presented in Gallegos v. Commissioner was whether the team roping expenses the petitioner claimed on his Schedule C as business losses were business or personal in nature. Giddy-up, ya’ll… Setting the Stage for Gallegos v. Commissioner First, this is a Judge Holmes opinion, so you know it’s going to be gold.

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Scott St. Amand March 2, 2021
Procedural Issues
Tax Opinions

Galloway v. Commissioner
T.C. Memo. 2021-24

On February 24, 2021, the Tax Court issued a Memorandum Opinion in the case of Galloway v. Commissioner (T.C. Memo. 2021-24). The primary issue presented in Galloway v. Commissioner was whether, during his CDP hearing, the petitioner was “improperly barred from resuscitating an offer-in-compromise” that had been rejected prior to the NFTL filing. Background to Galloway v. Commissioner By the time his second offer was rejected, the petitioner owed $81,500 in tax for 2014.  In

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Scott St. Amand February 24, 2021
Income Tax Issues
Tax Opinions

Anikeev v. Commissioner
T.C. Memo. 2021-23

On February 23, 2021, the Tax Court issued a Memorandum Opinion in the case of Anikeev v. Commissioner (T.C. Memo. 2021-23). The primary issue presented in Anikeev v. Commissioner was whether the “rewards” earned from the purchase of gift cards…a lot of gift cards…were income. Background to Anikeev v. Commissioner The petitioners were crafty Russians, who gamed the credit card reward system.  They joined a credit card rewards program and proceeded to purchase their credit

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Scott St. Amand February 23, 2021
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