The Index

tax court opinions | summarized & satirized

Income Tax Issues

These summaries examine all aspects of income taxes, such as receipt of income, deductions, individual liability, joint and several liability, innocent spouse relief, hobby losses, ordinary and necessary business expenses, and more.  These opinions focus primarily on personal income taxation, but issues of income taxation of entities is also discussed in a number of articles.

Procedural Issues

These summaries examine practical considerations in civil tax procedure including Collection Due Process appeals, Tax Court procedure, burden of proof, enforced collection mechanisms and defenses, statutes of limitations, administrative remedies to avoid taxes and penalties, and more.

Charitable Tax Issues

These summaries examine all aspects of IRC § 501(c)(3) organizations, including qualifying under the organizational and operational tests, charitable donations and deductions, valuing charitable gifts, record keeping requirements, conservation easements, compliance with DEFRA, the intersection between illegal substances and charitable organizations, and more.

Business Related Issues

These summaries examine corporations, partnerships, LLCs, and other entities with an eye towards worker classification, the centralized partnership audit regime, personal liability under the “at risk” rules of IRC § 465, as well as other issues related to the taxation of entities and their members, partners, and shareholders.

International Issues

These summaries broach the subject of the U.S. government’s authority on matters beyond its borders.  In particular, these articles examine U.S. persons’ international information return filing requirements, procedures for coming into compliance with such requirements, FIRPTA withholding, and other considerations for U.S. residents and ex-pats alike.

Penalties Under the Code

These summaries examine the 150+ civil penalties found in the Internal Revenue Code, as well as the procedures for asserting and assessing them, avoiding penalties through abatements and adjustments, defenses such as reasonable cause and reliance on a tax advisor, preparer penalties, and other assorted topics related to the plenitude of penalties at the disposal of the IRS.

Inside the Index,  you will find summaries of each Tax Court opinion published since January 1, 2020.  With each summary, we include the original text of the opinion for your reference.  Each summary is tagged with pertinent keywords, enabling you to find related cases and summaries. Where possible, we also provide links to related articles on Briefly Taxing. Scroll through the categories below, or click on the tabs for a summary of each category and the latest related opinions.