Income Tax Issues
Income Tax Issues

Knox v. Commissioner
T.C. Memo. 2021-126

On November 9, 2021, the Tax Court issued a Memorandum Opinion in the case of Knox v. Commissioner (T.C. Memo. 2021-126). The primary issue presented in Knox was whether the petitioners are entitled to a premium tax credit (PTC) and, if they are not, whether they are required to repay advance premium tax credit (APTC) payments of the PTC. Held: Yup and yeppers. Background to Knox v. Commissioner The petitioners were (and perhaps still are)

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Scott St. Amand March 30, 2022
Penalties Under the Code
Memorandum Opinions

Excelsior Aggregates v. Commissioner
T.C. Memo. 2021-125

On November 4, 2021, the Tax Court issued a Memorandum Opinion in the case of Excelsior Aggregates v. Commissioner (T.C. Memo. 2021-125). The primary issue presented in Excelsior Aggregates was whether the IRS complied with the prior supervisory approval requirement of IRC § 6751(b)(1) with respect to the numerous penalties asserted against the petitioner (IRC § 6662A and IRC § 6662(a), (b)(1)-(3), (d), (e), and (h)). Held: Executive Summary from the Tax Court in Excelsior

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Scott St. Amand March 29, 2022
Income Tax Issues
Income Tax Issues

Amburgey v. Commissioner
T.C. Memo. 2021-124

On November 1, 2021, the Tax Court issued a Memorandum Opinion in the case of Amburgey v. Commissioner (T.C. Memo. 2021-124). The primary issue presented in Amburgey v. Commissioner was whether the petitioners were required to repay an advance premium tax credit, or whether requiring them to do so was unconstitutional. Held: Pay up, petitioners. Background to Amburgey v. Commissioner The petitioners, a married couple, reported an adjusted gross income of $181,183 on their joint

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Scott St. Amand November 15, 2021
Penalties Under the Code
Memorandum Opinions

Cashaw v. Commissioner
T.C. Memo. 2021-123

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Cashaw v. Commissioner (T.C. Memo. 2021-123). The primary issue presented in Cashaw v. Commissioner was whether the petitioner is liable for trust fund recovery penalties. Held: Yup. Background to Cashaw v. Commissioner The petitioner was presented with difficult choices during her tenure as temporary chief administrator of a hospital. The hospital was under a state order freezing its bank accounts

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Scott St. Amand November 12, 2021
Procedural Issues
Memorandum Opinions

Hill v. Commissioner
T.C. Memo. 2021-121

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Hill v. Commissioner (T.C. Memo. 2021-121). The primary issue presented in Hill v. Commissioner was whether the petitioner’s remittance of $10.3 million to the IRS to be applied toward an anticipated gift tax liability for 2011, which remittance was designated as a “deposit” was a “deposit” or a “payment” for purposes of determining whether interest was due to the petitioner.

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Scott St. Amand November 10, 2021
Penalties Under the Code
Memorandum Opinions

Morris v. Commissioner
T.C. Memo. 2021-120

On October 25, 2021, the Tax Court issued a Memorandum Opinion in the case of Morris v. Commissioner (T.C. Memo. 2021-120). The primary issue presented in Morris v. Commissioner was whether the petitioner’s or liable for penalties for failure to timely file (IRC § 6651(a)(1)), failure to timely pay (IRC § 6651(a)(2)), and failure to pay estimated tax (IRC § 6654). Held: Yes. Yes, they were. Background to Morris v. Commissioner Mr. Morris was a

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Scott St. Amand November 8, 2021
Business Related Issues
Business Related Issues

Tribune Media Company v. Commissioner
T.C. Memo. 2021-122

On October 26, 2021, the Tax Court issued a Memorandum Opinion in the case of Tribune Media Company v. Commissioner (T.C. Memo. 2021-122). The primary issue presented in Tribune Media Company v. Commissioner was whether the Ricketts family (a partner of the petitioner in “Chicago Baseball Holdings, LLC”) entered into a “bona fide debt” for tax purposes. (You may remember these parties from the January 2020 decision of Chicago Baseball Holdings v. Commissioner, T.C. Memo. 2020-2).

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Scott St. Amand November 5, 2021
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