Penalties Under the Code
Tax Opinions

Llanos v. Commissioner
T.C. Memo. 2021-21

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Llanos v. Commissioner (T.C. Memo. 2021-21). The primary issue presented in Llanos v. Commissioner was whether the petitioner was liable for penalties under IRC § 6702. The Letter Return in Llanos v. Commissioner On December 1, 2014, the petitioner sent the IRS a letter entitled “Request for Audit Reconsideration for 2010, 2011, and 2012”. The letter states: “I fully intend

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Scott St. Amand February 22, 2021
Income Tax Issues
Tax Opinions

Rogers v. Commissioner
T.C. Memo. 2021-20

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Rogers v. Commissioner (T.C. Memo. 2021-20). The primary issue presented in Rogers v. Commissioner was whether the petitioner was eligible for innocent spouse relief under IRC § 6015(b), (c), or (f). The Wisconsin Tent & Pony Show in Rogers v. Commissioner The petitioner and her erstwhile husband owned the top[1] tent rental company in Madison, Wisconsin.  The petitioner also solely

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Scott St. Amand February 22, 2021
Penalties Under the Code
Tax Opinions

Friendship Creative Printers Inc. v. Commissioner
T.C. Memo. 2021-19

On February 22, 2021, the Tax Court issued a Memorandum Opinion in the case of Friendship Creative Printers Inc. v. Commissioner (T.C. Memo. 2021-19). The primary issue presented in Friendship Creative was whether the IRS abused its discretion in sustaining a proposed levy action in collection of over $200,000, arising out of the petitioner’s employment tax liabilities and associated penalties. Background to Friendship Creative Printers Inc. v. Commissioner In 2013, the petitioner did not timely

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Scott St. Amand February 22, 2021
Income Tax Issues
Tax Opinions

Blum v. Commissioner
T.C. Memo. 2021-18

On February 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Blum v. Commissioner (T.C. Memo. 2021-18). The primary issue presented in Blum v. Commissioner was whether the petitioner was entitled to exclude from her gross income the $125,000 settlement payment (from a suit against former attorneys who bungled a personal injury lawsuit on petitioner’s behalf) as damages received “on account of personal physical injuries or physical sickness” under IRC §

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Scott St. Amand February 18, 2021
Business Related Issues
Tax Opinions

Estate of Warne v. Commissioner
T.C. Memo. 2021-17

On February 18, 2021, the Tax Court issued a Memorandum Opinion in the case of Estate of Warne v. Commissioner (T.C. Memo. 2021-17). The primary issue presented in Estate of Warne v. Commissioner was whether the IRS erred in increasing the value of the estate and the LLCs and by denying a giant charitable deduction ($25 million).  Specifically, the issues in Estate of Warne v. Commissioner concerned valuation of certain family LLCs, discounts for lack

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Scott St. Amand February 18, 2021
Penalties Under the Code
Tax Opinions

Kramer v. Commissioner
T.C. Memo. 2021-16

On February 16, 2021, the Tax Court issued a Memorandum Opinion in the case of Kramer v. Commissioner (T.C. Memo. 2021-16). The primary issues presented in Kramer v. Commissioner were whether the petitioners were in default and whether the IRS carried its various burdens of production and proof with respect to the deficiencies asserted. Background to Kramer v. Commissioner The petitioners are not what you would call “cooperative” or “responsible” taxpayers. Although they brought petition

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Scott St. Amand February 16, 2021
Business Related Issues
Tax Opinions

Little Sandy Coal Co. Inc. v. Commissioner
T.C. Memo. 2021-15

On February 11, 2021, the Tax Court issued a Memorandum Opinion in the case of Little Sandy Coal Co. Inc. v. Commissioner (T.C. Memo. 2021-15). The primary issue presented in Little Sandy Coal Co. Inc. v. Commissioner was whether the activities of the petitioner’s subsidiary’s research in developing the ships constituted elements of a process of experimentation for purposes of IRC § 41(d)(1)(C) and Treas. Reg. § 1.41-4(a)(6). Holdings, in Brief in Little Sandy Coal Co.

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Scott St. Amand February 11, 2021
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