Jason Freeman at Freeman Law

Tax Court in Brief | Colbert v. Commissioner | Accuracy-Related Penalties and IRS Procedural Requirements

7/20/2022 / Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Estate of DeMuth v. Commissioner | Are Uncashed Gift Checks Includable in an Estate for Federal Income Tax...

7/19/2022 / Deficiency Notices , Gifts , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Whistleblower 972-17W v. Commissioner | Whistleblower Entitled to Unredacted (Mainly) Administrative Record

7/19/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns , Whistleblower Protection Policies , Whistleblowers

Tax Court in Brief | Wolpert v. Commissioner | Schedule C Itemized Business Expense Deductions and Substantiation

Tax Litigation: The Week of July 4th, 2022, through July 8th, 2022 Barrington v. Commissioner, T.C. Memo. 2022-68 | July 6, 2022 | Buch, J.| Dkt. No. 1781-14 Couturier v. Commissioner, No. 19714-16, T.C. Memo 2022-69 | July...more

7/18/2022 / Business Expenses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Couturier v. Commissioner | Taxation of Excess Contributions from IRA

7/18/2022 / Excise Tax , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Barrington v. Commissioner | Guilty Plea to Determine Tax Liability and Constructive Divident versus...

Tax Litigation: The Week of July 4th, 2022, through July 8th, 2022 Couturier v. Commissioner, No. 19714-16, T.C. Memo 2022-69 | July 6, 2022 | Lauber | Dkt. 19714-16 Wolpert v. Commissioner, T.C. Memo. 2022-70 | July 7, 2022...more

7/18/2022 / Guilty Pleas , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Ziroli v. Commissioner | Is a Disgorgement Payment a Deductible Business Expense under Section 162?

Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Estate of DeMuth, v. Comm’r, T.C. Memo. 2022-72 | July 12, 2022 | Jones, J. | Dkt. No. 18724-19 Whistleblower 972-17W v. Comm’r, 159 T.C. No. 1 | July 13,...more

7/15/2022 / Business Expenses , Business Taxes , Disgorgement , Income Taxes , Internal Revenue Code (IRC) , IRS , Section 162 , Section 162(f) , Tax Court , Tax Deductions , Tax Planning

Tax Court in Brief | Kotrides v. Commissioner | Collection Due Process, Abuse of Discretion, and Summary Judgment

Tax Litigation: The Week of June 27th, 2022, through July 1st, 2022 Serna v Commissioner, T.C. Memo. 2022-66 | June 27, 2022 | Urda, J.| Dkt. No. 13202-19L Pedersen v. Commissioner, T.C. Summary Opinion 2022-11 | June 28,...more

7/8/2022 / Abuse of Discretion , Income Taxes , IRS , Motion for Summary Judgment , Tax Court , Tax Debt , Tax Liability , Tax Liens , Tax Planning , Tax Returns

Tax Court in Brief | Hatfield v. Commissioner | Frivolous Arguments

Tax Litigation: The Week of June 13th, 2022, through June 17th, 2022 Phillips v. Comm’r, T.C. Memo. 2022-58 | June 13, 2022 | Lauber, J. | Dkt. No. 18553-21L Romana v. Commissioner, T.C. Summary Opinion 2022-9 | June 16,...more

6/24/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

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

6/24/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Trust Fund Recovery Penalty (TFRP)

Tax Court in Brief | Phillips v. Commissioner | Collection Due Process and No Abuse of Discretion

6/24/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Hatfield v. Commissioner | Taxable Wages, Additional Taxes, and Frivolous Arguments

6/23/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns , W-2

Tax Court in Brief | Howland v. Commissioner | Mortgage Interest Deduction in Foreclosure Sale and Accuracy-Related Penalty

6/23/2022 / Burden of Proof , Foreclosure , Income Taxes , IRS , Mortgage Interest , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Romana v. Commissioner | Miscellaneous Itemized Business Expenses and Accuracy-Related Penalty

6/23/2022 / Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Musselwhite v. Commissioner | Loss in Sale of Real Estate: Ordinary Loss or Capital Loss?

Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Pocock v. Commissioner, T.C. Memo. 2022-55 | June 6, 2022 | Vasquez, J.| Dkt. No. 12558-17 Consolidated with Dkt. No. 23569-17L Spencer v Commissioner, T.C....more

6/22/2022 / Capital Losses , IRS , Real Estate Investments , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Spencer v. Commissioner | Itemized Business Deductions and Substantiation Requirements

Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Pocock v. Commissioner, T.C. Memo. 2022-55 | June 6, 2022 | Vasquez, J.| Dkt. No. 12558-17 Consolidated with Dkt. No. 23569-17L Musselwhite v. Commissioner,...more

6/22/2022 / Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Chinweze v. Commissioner | Collection Due Process and IRS Form 3877 Mailing Requirements

6/21/2022 / Debt Collection , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Pocock v. Commissioner | Equitable Innocent Spouse Relief Under 6015(f)

6/21/2022 / Criminal Investigations , Income Taxes , Innocent Spouse Exception , IRS , Joint and Several Liability , Joint Tax Returns , Tax Court , Tax Liability , Tax Returns

Restricted Appeals in Texas

Restricted Appeals A restricted appeal is a direct attack on a judgment. To be entitled to a restricted appeal, an appellant must demonstrate several elements described below. ...more

6/21/2022 / Appeals , Jurisdiction , Litigation Strategies , Rules of Appellate Procedure , TX Supreme Court

Tax Court in Brief | Ezekwo v. Commissioner | Passport Revocation for Seriously Delinquent Tax Debt

Tax Litigation: The Week of May 30th, 2022, through June 3rd, 2022 Ezekwo v Commissioner, T.C. Memo. 2022-54 | May 31, 2022 | Lauber, J.| Dkt. No. 15454-21P...more

6/16/2022 / Income Taxes , IRS , Tax Court , Tax Debt , Tax Liability , Tax Planning , Tax Returns

Bills of Review in Texas

What is a Bill of Review? A bill of review is an equitable proceeding, seeking to set aside a prior judgment that is no longer subject to challenge by a motion for new trial or appeal...more

6/9/2022 / Collateral Attack , Default Judgment , Defense Strategies , Litigation Strategies , Standard of Review , Trial Preparation

Texas Courts and The Doctrine of Res Judicata

Texas Courts and The Doctrine of Res Judicata The doctrine of res judicata, or claim preclusion, bars a second action by parties and those in privity with them on matters actually litigated in a previous suit, as well as...more

6/8/2022 / Affirmative Defenses , Claim Preclusion , Collateral Estoppel , Counterclaims , Issue Preclusion , Res Judicata

Tax Court in Brief | Albrecht v. Commissioner | Charitable Contributions and Contemporaneous Written Acknowledgements

6/8/2022 / Charitable Deductions , Charitable Donations , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Genecure, LLC v. Commissioner | Capital Expenses, QTDP Recapture Tax, Fraud-Related Penalty Requirements

6/8/2022 / Burden of Proof , Business Expenses , Federal Rules of Evidence , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , TEFRA

Exempt Payments to Non-Resident Aliens and Federal Withholding

Exempt Payments to Non-Resident Aliens and Federal Withholding - Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to...more

6/8/2022 / Employment Tax , Income Taxes , Non-Resident Aliens , Non-Resident Income Taxes , Reporting Requirements , Tax Liability , Wage and Hour , Withholding Tax

Jason Freeman

Freeman Law

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