Jason Freeman on Income Taxes

Tax Court in Brief | DelPonte v. Commissioner | Innocent Spouse Relief and Authority of IRS Chief Counsel

5/10/2022 / Income Taxes , Innocent Spouse Exception , IRS , Joint Tax Returns , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Mighty v. Commissioner | Collection Due Process and 1,862 Days from Notice of Deficiency to Determination

Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mazzei v. Comm’r, T.C. Memo 2022-43 |...more

5/10/2022 / Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Sestak v. Commissioner | Badges of Fraud, Bribery, and Violation of Sharply Defined Public Policy

Tax Litigation: The Week of April 25th, 2022, through April 29th, 2022 Sestak v. Comm’r, TC Memo. 2022-41| April 25, 2022 | Weiler, J. | Dkt. No. 17285-18...more

5/6/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Fraud , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Valentine v. Commissioner | Taxability of Military Pension and Disability Payments and Business Expense...

Tax Litigation: The Week of April 25th, 2022, through April 29th, 2022 Valentine v. Comm’r, TC Memo. 2022-42| April 28, 2022 | Gustafson, J. | Dkt. No. 6724-19...more

5/6/2022 / Business Expenses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Veterans Administration

The Doctrine of Constructive Receipts

Under the doctrine of constructive receipt, a cash-basis taxpayer who has an unrestricted right to receive income is treated as though they actually received the income–even if they did not. Thus, even when a taxpayer has...more

5/4/2022 / Federal Taxes , Income Taxes , IRS , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Treece Financial Services Group v. Comm’r/Treece Investment Advisory Corp. v. Comm’r | VCSP and IRS...

4/29/2022 / Employment Tax , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , VCSP

Tax Court in Brief | Sezonov v. Commisioner | Side Gigs and Passive Activities

4/29/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Bindel v. Commissioner | FYI: Wages are Taxable . . . Yes, Really

Tax Litigation: The Week of April 18th, 2022, through April 22nd, 2022 Treece Financial Services Group, v. Comm’r, 158 T.C. No. 6 | April 19, 2022 | Kerrigan, J. | Dkt. No. 20850-19 Sezonov. Comm’r, TC Memo. 2022-40| April...more

4/29/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning

The Section 962 Election

For years, section 962 was a relatively obscure tax-planning mechanism. The Tax Cuts & Jobs Act, however, changed that, pushing the so-called section 962 election into vogue. Section 962 allows an individual shareholder of a...more

4/20/2022 / Controlled Foreign Corporations , Corporate Taxes , Foreign Corporations , Foreign Tax , Foreign Tax Credits , GILTI tax , Income Taxes , Tax Cuts and Jobs Act , Tax Planning

The IRS and Nominee Liability

Under the Internal Revenue Code, the IRS can satisfy a tax deficiency by imposing a lien on any “property” or “rights to property” belonging to the taxpayer. The statutory language is broad and reaches virtually every...more

4/19/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Liability , Tax Liens , Tax Planning

Tax Court in Brief | Pediatric Impressions Home Health, Inv. v. Comm’r | Common Law Employees, Section 530 Relief, and Penalties

4/19/2022 / Employment Tax , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Mihalik v. Commissioner | “De Minimus” Fringe Benefit Under Sec. 132

Tax Litigation: The Week of April 11th, 2022, through April 15th, 2022 The REDI Foundation, Inc. v. Comm’r, T.C. Memo. 2022-34 |April 11, 2022 |Nega, J. | Dkt. No. 23715-18 Pediatric Impressions Home Health, Inc. v. Comm’r,...more

4/19/2022 / Employee Benefits , Fringe Benefits , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court

Tax Court in Brief | The REDI Foundation, Inc. v. Commissioner | Statutory Employee, FICA, and Form 941

Tax Litigation: The Week of April 11th, 2022, through April 15th, 2022 Mihalik v. Comm’r | April 13, 2022 | Gustafson, D. | Dkt. No. 7881-19 Pediatric Impressions Home Health, Inc. v. Comm’r, T.C. Memo. 2022-35 | April 12,...more

4/19/2022 / Federal Employees , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

The Source of Income from the Sale of Personal Property

The Source of Income from the Sale of Personal Property Generally, income from the sale of personal property is “sourced” to the residence of the seller. If the seller is a U.S. tax resident the source of the income is deemed...more

4/15/2022 / Capital Gains , Foreign Corporations , Income Taxes , Intangible Property , Internal Revenue Code (IRC) , Personal Property Tax , Property Tax

Tax Court in Brief | Metz v. Commissioner | Interplay of Criminal Tax, Civil Tax, and Civil Penalties

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022 / Criminal Penalties , Income Taxes , Internal Revenue Code (IRC) , Reporting Requirements , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Webert v. Commissioner | Sale of Principal Residence

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022 / Genuine Issue of Material Fact , Income Taxes , IRS , Joint Tax Returns , Tax Court , Tax Liability , Tax Returns

Tax Court in Brief | Norberg v. Commissioner | Currently Not Collectible

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Continuing Life Communities Thousand Oaks LLC v. Comm’r | IRS Discretion to Change Methods of Accounting and...

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022 / Abuse of Discretion , Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Scholtz v. Commissioner | Itemized Deductions, Charitable Contributions and Unreimbursed Employee Expenses

4/14/2022 / Business Expenses , Charitable Donations , Income Taxes , Itemized Deductions , Tax Court , Tax Deductions , Tax Planning

Jason Freeman

Freeman Law

Readers' Choice Awards

Popular Topics by This Author

Latest Posts › Income Taxes

Tax Court in Brief | DelPonte v. Commissioner | Innocent Spouse Relief and Authority of IRS Chief Counsel

Tax Court in Brief | Mighty v. Commissioner | Collection Due Process and 1,862 Days from Notice of Deficiency to Determination

Tax Court in Brief | Sestak v. Commissioner | Badges of Fraud, Bribery, and Violation of Sharply Defined Public Policy

Tax Court in Brief | Valentine v. Commissioner | Taxability of Military Pension and Disability Payments and Business Expense...

The Doctrine of Constructive Receipts

Tax Court in Brief | Treece Financial Services Group v. Comm’r/Treece Investment Advisory Corp. v. Comm’r | VCSP and IRS...

Tax Court in Brief | Sezonov v. Commisioner | Side Gigs and Passive Activities

Tax Court in Brief | Bindel v. Commissioner | FYI: Wages are Taxable . . . Yes, Really

The Section 962 Election

The IRS and Nominee Liability

Tax Court in Brief | Pediatric Impressions Home Health, Inv. v. Comm’r | Common Law Employees, Section 530 Relief, and Penalties

Tax Court in Brief | Mihalik v. Commissioner | “De Minimus” Fringe Benefit Under Sec. 132

Tax Court in Brief | The REDI Foundation, Inc. v. Commissioner | Statutory Employee, FICA, and Form 941

The Source of Income from the Sale of Personal Property

Tax Court in Brief | Metz v. Commissioner | Interplay of Criminal Tax, Civil Tax, and Civil Penalties

Tax Court in Brief | Webert v. Commissioner | Sale of Principal Residence

Tax Court in Brief | Norberg v. Commissioner | Currently Not Collectible

Tax Court in Brief | Continuing Life Communities Thousand Oaks LLC v. Comm’r | IRS Discretion to Change Methods of Accounting and...

Tax Court in Brief | Scholtz v. Commissioner | Itemized Deductions, Charitable Contributions and Unreimbursed Employee Expenses

Tax Court in Brief | Middleton v. Commissioner | Trust Fund Recovery Penalty Assessment and Collection Due Process

Tax Court in Brief | Salter v. Commissioner | Substitute for Return and Itemized Deductions

Tax Treaties and Exempt Income

Tax Court in Brief | Golditch v. Commissioner | Collection Due Process and Frivolous Arguments

Tax Court in Brief | Addis v. Commissioner | Collection Due Process and Frivolous Positions

Tax Court in Brief | Villanueva v. Comm’r | Net Operating Losses and Carry Forward

Jason Freeman

Readers' Choice Awards

Popular Topics by This Author

Latest Posts › Income Taxes

"My best business intelligence, in one easy email…"