Penalties Under the Code
Memorandum Opinions

Jenkins v. Commissioner
T.C. Memo. 2021-54

On May 10, 2021, the Tax Court issued a Memorandum Opinion in the case of Jenkins v. Commissioner (T.C. Memo. 2021-54). The primary issues presented in Jenkins v. Commissioner was whether the IRS has proven fraud, and the amount of unreported income for the consolidated petitioners. Just a Head’s Up re: Jenkins v. Commissioner This opinion by Judge Holmes contains a “waddle” of penguins that speak in French, a forged Kerguelenois diplomatic passport, and a

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

Flynn v. Commissioner
T.C. Memo. 2021-43

On April 13, 2021, the Tax Court issued a Memorandum Opinion in the case of Flynn v. Commissioner (T.C. Memo. 2021-43). The primary issue presented in Flynn v. Commissioner was whether the petitioner’s failure to file returns for 1999, 2000, and 2001 was fraudulent. Tax Court’s Holding in Flynn v. Commissioner:   It’s a Damn Conspiracy (No, Really, It Is) The petitioner took part in a bit of a criminal conspiracy, which bilked 577 suckers

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Scott St. Amand April 13, 2021
Penalties Under the Code
Memorandum Opinions

Walton v. Commissioner
T.C. Memo. 2021-40

On March 30, 2021, the Tax Court issued a Memorandum Opinion in the case of Walton v. Commissioner (T.C. Memo. 2021-40). The primary issue presented in Walton was whether the petitioner qualified for the reasonable cause exception to the imposition of an accuracy-related penalty. Background to Walton v. Commissioner The petitioner was a New Yorker,[1] who failed to report $170,000 in nonemployee compensation in 2015. Strike one and two. The petitioner was terminated from her

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Scott St. Amand March 30, 2021
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
Penalties Under the Code
Full Tax Court Opinions

Beland v. Commissioner
156 T.C. No. 5

On March 1, 2021, the Tax Court issued its opinion in Beland v. Commissioner (156 T.C. No. 5). The underlying issue presented in Beland v. Commissioner was whether the civil fraud penalty was not timely approved pursuant to IRC § 6751(b)(1). Background to Beland v. Commissioner The petitioners filed a joint return for 2011.  The IRS audited the return and required the petitioners to attend an in-person closing conference.  During the conference, the revenue agent

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Scott St. Amand March 1, 2021
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