Jason Freeman

Jason Freeman

Freeman Law

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Tax Court in Brief | Caldwell v. Commissioner | Employer Disability Compensation is Taxable Income to Employee

Tax Litigation: The Week of May 16th, 2022, through May 20th, 2022 Ibrahim v. Commissioner, TC Summary Opin. 2022-7| May 16, 2022 | Weiler, J. | Dkt. No. 10750-20S Caldwell v. Comm’r, T.C. Memo 2022-51 | May 20, 2022 |...more

6/1/2022  /  Income Taxes , Internal Revenue Code (IRC) , IRS , Payroll Taxes , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Ibrahim v. Commissioner | Deduction of Alimony or Separation Maintenance Payments

Tax Litigation: The Week of May 16th, 2022, through May 20th, 2022 Caldwell v. Comm’r, T.C. Memo 2022-51 | May 20, 2022 | Lauber, J. | Dkt. No. 3333-19. Ibrahim v. Commissioner, TC Summary Opin. 2022-7| May 16, 2022 |...more

5/31/2022  /  Alimony , Divorce , Income Taxes , Internal Revenue Code (IRC) , Separation Agreement , Tax Court , Tax Deductions , Tax Liability , Tax Planning

Tax Court in Brief | Harrison v. Commissioner | Itemized Deductions, Charitable Contributions, Passive Income

Tax Litigation:  The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Rogerson v. Commissioner, TC Memo. 2022-49| May 12, 2022 | Toro, J. |...more

5/31/2022  /  Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Evert v. Commissioner | Extending Notice of Deficiency Deadline and Duress as an Affirmative Defense

Tax Litigation: The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Rogerson v. Commissioner, TC Memo. 2022-49| May 12, 2022 | Toro, J. |...more

5/27/2022  /  Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Jackson v. Commissioner | What’s at Issue in Reviewing the Determination of a Collection Due Process Hearing?

Tax Litigation:  The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Rogerson v. Commissioner, TC Memo. 2022-49| May 12, 2022 | Toro, J. |...more

5/26/2022  /  Due Process , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Rogerson v. Commissioner | Passive Income, Rent of Yachts, and Reliance on Competent Tax Counsel

Tax Litigation: The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Jackson v. Comm’r, T.C. Memo. 2022-50 | May 12, 2022 | Vasquez, J. |...more

5/26/2022  /  Income Taxes , IRS , Rental Property , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Lewis v. Commissioner | Appealable Determination of Whistleblower Award

Tax Litigation: The Week of May 9th, 2022, through May 13th, 2022 Rogerson v. Commissioner, TC Memo. 2022-49| May 12, 2022 | Toro, J. | Dkt. No. 5848-20 Jackson v. Comm’r, T.C. Memo. 2022-50 | May 12, 2022 | Vasquez, J. |...more

5/18/2022  /  IRS , Tax Court , Whistleblower Awards , Whistleblower Protection Policies , Whistleblowers

Hedge Funds 101: An Introduction to Tax Issues

Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more

5/11/2022  /  Carried Interest , Carried Interest Tax Rates , Corporate Taxes , FIRPTA , Foreign Investment , Hedge Funds , Internal Revenue Code (IRC) , Investment Management , Private Equity , Private Equity Funds , Tax Cuts and Jobs Act , Tax Planning

Tax Court in Brief | Wolfson v. Commissioner | Collection Due Process and Review of Settlement Officer Performance of Duty

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 Mighty v. Comm’r, TC Memo. 2022-44|...more

5/11/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Trust Fund Recovery Penalty (TFRP)

Tax Court in Brief | Podlucky v. Commissioner | $34M Jewelry in a Secret Room, Constructive Receipt, Innocent Spouse, and Putative...

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 Mighty v. Comm’r, TC Memo. 2022-44|...more

5/11/2022  /  Abuse of Discretion , Income Taxes , IRS , Joint and Several Liability , Joint Tax Returns , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Mazzei v. Commissioner | Law of the Case, Prevailing Party, and “Substantially Justified”

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 Mighty v. Comm’r, TC Memo. 2022-44|...more

5/10/2022  /  Income Taxes , IRS , Prevailing Party , Roth IRA , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

The Alter Ego Doctrine and Taxes

The Alter Ego Doctrine and Taxes What is an “alter ego?” The phrase is Latin, translating to “second I,” “another I,” or “other self.” In the federal tax context, the alter ego doctrine comes into play where the IRS...more

5/10/2022  /  Alter Ego , Corporate Governance , Corporate Taxes , Income Taxes , IRS , Limited Liability Company (LLC) , Piercing the Corporate Veil , Tax Liability , Tax Planning

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

Tax Litigation:  The Week of May 2nd, 2022, through May 6th, 2022 Mighty v. Comm’r, TC Memo. 2022-44| May 4, 2022 | Lauber, J. | Dkt. No. 19064-21L Mazzei v. Comm’r, T.C. Memo 2022-43 | May 2, 2022 | Thornton, J. | Dkt. No....more

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

Successor Liability for Unpaid Taxes

Generally, the purchaser of assets does not assume the liabilities of the seller.  Successor liability, however, is an exception to the general rule. Under the successor-liability doctrine, the IRS may seek to recover unpaid...more

5/6/2022  /  Fraudulent Transfers , IRS , Successor Liability , Tax Liability , Tax Planning

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...

Tax Litigation:  The Week of April 18th, 2022, through April 22nd, 2022 Sezonov. Comm’r, TC Memo. 2022-40| April 20, 2022 | Marvel, J. | Dkt. No. 26650-17 Bindel v. Commissioner |April 20, 2022 | Urda, P. | Dkt. No. 9552-19...more

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

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 Bindel v. Commissioner |April 20, 2022 |...more

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

Texas Courts and Subject Matter Jurisdiction

Subject-matter jurisdiction concerns a court’s power to hear a case. Without it, a court does not have authority to decide a case. Subject matter jurisdiction is distinct from the concept of personal jurisdiction, which...more

4/29/2022  /  Jurisdiction , Personal Jurisdiction , Question of Law , Separation of Powers , Standing , State Constitutions , Subject Matter Jurisdiction , TX Supreme Court

The Texas Constitution and the Open Courts Provision

The Texas Constitution’s open courts provision ensures that litigants receive their day in court. Tex. Const. Ann. art. 1, § 13 ...more

4/22/2022  /  Common Law Claims , Constitutional Challenges , State Constitutions , TX Supreme Court

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
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