Income Tax Issues
Income Tax Issues

Hoops LP v. Commissioner
T.C. Memo. 2022-9

On February 23, 2022, the Tax Court issued a Memorandum Opinion in the case of Hoops LP v. Commissioner (T.C. Memo. 2022-9). The primary issues presented in Hoops LP v. Commissioner were whether partnership was entitled to deduct deferred compensation owed to two of its basketball franchise’s players, and whether the partnership was required to take into account the amount of its deferred compensation liability for players when computing its taxable gain or loss from

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Scott St. Amand May 16, 2022
Income Tax Issues
Income Tax Issues

Harwood v. Commissioner
T.C. Memo. 2022-8

On February 15, 2022, the Tax Court issued a Memorandum Opinion in the case of Harwood v. Commissioner (T.C. Memo. 2022-8). The primary issue presented in Harwood was whether the taxpayer adequately substantiated his deductions for travel, residence, and “other” such deductions. Background to Harwood v. Commissioner During the years at issue, Mr. Harwood worked as a steamfitter and brazier on construction projects in Washington and Oregon. Mr. Harwood joined Plumber and Steamfitters Local 598

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Scott St. Amand May 13, 2022
Penalties Under the Code
Memorandum Opinions

Williams v. Commissioner
T.C. Memo. 2022-7

On February 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Williams v. Commissioner (T.C. Memo. 2022-7). The primary issues presented in Williams were (i) whether the disallowance of the petitioner’s deductions was warranted; and (ii) whether frivolous position penalty was warranted. A Brief Background of Williams v. Commissioner The IRS issued a notice of deficiency, in which it disallowed certain deductions claimed by the petitioner (Larry) in connection with his

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Scott St. Amand May 12, 2022
Income Tax Issues
Income Tax Issues

Slone v. Commissioner
T.C. Memo. 2022-6

On February 7, 2022, the Tax Court issued a Memorandum Opinion in the case of Slone v. Commissioner (T.C. Memo. 2022-6). The primary issues presented in Slone were (i) whether the IRS bore the burden of production to show timely supervisory approval of the accuracy-related penalty; (ii) whether the IRS was entitled to maintain claims against the petitioners and the trusts at issue. Editor’s Note to Slone v. Commissioner The contempt that Judge Lauber (appropriately)

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Scott St. Amand May 11, 2022
Procedural Issues
Memorandum Opinions

Flynn v. Commissioner
T.C. Memo. 2022-5

On February 3, 2022, the Tax Court issued a Memorandum Opinion in the case of Flynn v. Commissioner (T.C. Memo. 2022-5). The primary issue presented in Flynn was whether the settlement officer abused her discretion in rejecting an offer-in-compromise based on reporting housing expenses which deviated from the IRS’s standard housing amount allowance. Background to Flynn v. Commissioner As of February 2018, Mr. Flynn’s outstanding 2012–14 tax liabilities totaled $15,557. To collect this amount, the

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Scott St. Amand May 10, 2022
Income Tax Issues
Income Tax Issues

Estate of Washington v. Commissioner
T.C. Memo. 2022-4

On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Estate of Washington v. Commissioner (T.C. Memo. 2022-4). The primary issue presented in Estate of Washington was whether offers-in-compromise presented by the estate qualified for effective tax administration consideration. No George and Martha Mr. Washington (Tony) wed Mrs. Washington (Lenda) in 1981. They had one child. They divorced in 2006. Mr. Washington had unpaid income tax liabilities for 2008, 2009,

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Scott St. Amand May 9, 2022
Income Tax Issues
Income Tax Issues

Larson v. Commissioner
T.C. Memo. 2022-3

On February 2, 2022, the Tax Court issued a Memorandum Opinion in the case of Larson v. Commissioner (T.C. Memo. 2022-3). The primary issue presented in Larson was whether stock in an S corporation was subject to a substantial risk of forfeiture. Held: Nope. Background (and not a Particularly Flattering One for the petitioner) in Larson v. Commissioner Mr. Larson is a criminal. That’s not my opinion. That was the decision of the Southern District of

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Scott St. Amand May 6, 2022
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