Income Tax Issues
Income Tax Issues

Huff v. Commissioner
T.C. Memo. 2021-140

On December 21, 2021, the Tax Court issued a Memorandum Opinion in the case of Huff v. Commissioner (T.C. Memo. 2021-140). The primary issue presented in Huff was whether the petitioners’ miniature donkey breeding operation was an activity engaged in for profit within the meaning of IRC § 183. Held: Actually, yes. Author’s Note on Huff v. Commissioner Judge Patrick J. Urda (who delivered this opinion) was a Classics major at Notre Dame, where he

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Scott St. Amand April 26, 2022
Income Tax Issues
Income Tax Issues

Skolnick v. Commissioner
T.C. Memo. 2021-139

On December 16, 2021, the Tax Court issued a Memorandum Opinion in the case of Skolnick v. Commissioner (T.C. Memo. 2021-139). The primary issue presented in Skolnick was whether the petitioner’s “horse activity,” undertaken through his LLC, was an activity not engaged in for profit within the meaning of IRC § 183 during 2010-2013. Held: Petitioners were just horsing around, but they had reasonable cause to avoid the accuracy-related penalties. On Horse Breeding and Miniature

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Scott St. Amand April 25, 2022
Income Tax Issues
Income Tax Issues

Safaryan v. Commissioner
T.C. Memo. 2021-138

On December 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Safaryan v. Commissioner (T.C. Memo. 2021-138). The primary issue presented in Safaryan was whether the petitioners were entitled to deduct certain Schedule C expenses for car and truck expenses, travel expenses, and “other” expenses. Held: Not so much. Background to Safaryan v. Commissioner In 2012 or 2013 the petitioner-husband purchased 10 acres of property in Newberry Springs, California. The property

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Scott St. Amand April 24, 2022
Penalties Under the Code
Memorandum Opinions

Soni v. Commissioner
T.C. Memo. 2021-137

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Soni v. Commissioner (T.C. Memo. 2021-137). The primary issues presented in Soni were (1) whether the petitioners filed a valid joint return; (2) whether the period of limitations for assessment of tax under IRC § 6501(a) and (c)(4) expired before the issuance of the notice of deficiency; (3) whether the petitioners are liable for an addition to tax under IRC

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Scott St. Amand April 23, 2022
Business Related Issues
Business Related Issues

Chan v. Commissioner
T.C. Memo. 2021-136

On December 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Chan v. Commissioner (T.C. Memo. 2021-136). The primary issue presented in Chan was whether the entity in question (which filed a Form 2553, Election by a Small Business Corporation, by which it elected to be treated as an S corporation) was an S corporation or a C corporation. Background to Chan v. Commissioner The petitioners operated a restaurant in California

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Scott St. Amand April 22, 2022
Procedural Issues
Memorandum Opinions

FAB Holdings LLC v. Commissioner
T.C. Memo. 2021-135

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of FAB Holdings LLC v. Commissioner (T.C. Memo. 2021-135). The primary issue presented in FAB Holdings was whether the statutory notices of deficiency (SNODs) were timely sent based upon a cockamamy argument that the petitioners’ CPA was a “promoter” because the petitioners paid for his services. Held: The Tax Court was “not persuaded” by such argument. Background to FAB Holdings LLC

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Scott St. Amand April 21, 2022
Procedural Issues
Memorandum Opinions

O’Donnell v. Commissioner
T.C. Memo. 2021-134

On November 30, 2021, the Tax Court issued a Memorandum Opinion in the case of O’Donnell v. Commissioner (T.C. Memo. 2021-134). The primary issue presented in O’Donnell was whether the settlement officer abused his discretion in sustaining the collection action against a taxpayer who had a “blatant disregard for voluntary compliance.” Background to O’Donnell v. Commissioner Let me begin by saying that James O’Donnell is not a paragon of tax compliance. According to Judge Lauber,

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Scott St. Amand April 20, 2022
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