Jason Freeman

Jason Freeman

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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 | 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 | Phillips v. Commissioner | Collection Due Process and No Abuse of Discretion

Tax Litigation: The Week of June 13th, 2022, through June 17th, 2022 Hatfield v. Comm’r, T.C. Memo. 2022-59 | June 13, 2022 | Lauber, J. | Dkt. Nos. 7327-20, 1500-21 Chavis v. Comm’r, 158 T.C. No. 8 | June 15, 2022 | Lauber,...more

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

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

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 Chavis v. Comm’r, 158 T.C. No. 8 | June 15, 2022 | Lauber, J. |...more

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

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 Chavis v. Comm’r, 158 T.C. No. 8 | June 15, 2022 | Lauber, J. |...more

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

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 | Albrecht v. Commissioner | Charitable Contributions and Contemporaneous Written Acknowledgements

Tax Litigation: The Week of May 23rd, 2022, through May 27th, 2022 Genecure, LLC v. Comm’r, T.C. Memo 2022-52 | May 23, 2022 | Jones, J. | Dkt. No. 14916-15. Albrecht v. Comm’r, T.C. Memo 2022-53 | May 25, 2022 | Greaves, J....more

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

Tax Litigation: The Week of May 23rd, 2022, through May 27th, 2022 Albrecht v. Comm’r, T.C. Memo 2022-53 | May 25, 2022 | Greaves, J. | Dkt. No. 13314-20. Genecure, LLC v. Comm’r, T.C. Memo 2022-52 | May 23, 2022 | Jones, J....more

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

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 | 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 | 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

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

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

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 | Scholtz v. Commissioner | Itemized Deductions, Charitable Contributions and Unreimbursed Employee Expenses

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 Salter v. Comm’r, T.C. Memo. 2022-9 |April 5, 2022 |Lauber, J. |...more

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

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

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4, 2022 |Panuthos, J. | Dkt. No. 20743-19S Salter v. Comm’r, T.C. Memo. 2022-9 |April 5, 2022 |Lauber,...more

4/14/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Trust Fund Recovery Penalty (TFRP)

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

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

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

Tax Litigation:  The Week of March 28, 2022, through April 1, 2022 Addis v. Comm’r, T.C. Memo. 2022-24 | March 28, 2022 |Urda, J. | Dkt. No. 12140-20L Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt....more

4/4/2022  /  Business Taxes , Corporate Taxes , Income Taxes , Net Operating Losses , Tax Deductions

Tax Court in Brief | Oxbow Bend, LLC v. Comm’r | Conservation Easement and “Initial Determination” of Penalties

Tax Litigation: The Week of March 21, 2022, through March 25, 2022 Oxbow Bend, LLC v. Comm’r, T.C. Memo. 2022-23 | March 21, 2022 |Lauber, J. | Dkt. No. 12718-19 Short Summary: This case involves a charitable contribution...more

3/31/2022  /  Charitable Donations , Conservation Easements , IRS , Tax Deductions , Tax Liability , Tax Planning

Tax Court in Brief | Pickens Decorative Stone, LLC v. Comm’r | Syndicated Conservation Easement and “In Perpetuity”

Tax Litigation: The Week of March 14, 2022, through March 18, 2022 Hamilton v. Comm’r, T.C. Memo. 2022-21 | March 15, 2022 |Urda, J. | Dkt. No. 139-19L AptarGroup, Inc. v. Comm’r, 158 T.C. No. 4 | March 16, 2022 |Goeke, J. |...more

3/24/2022  /  Charitable Deductions , Conservation Easements , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning

Tax Court in Brief | Walters v. Comm’r | Deductibility of “For Profit” Business Expenses

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Cosio v. Comm’r, T.C. Memo. 2022-18 | March 9, 2022 | Weiler, J. | Dkt....more

3/15/2022  /  Business Expenses , Business Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , Section 162 , Section 183 , Tax Court , Tax Deductions , Tax Planning
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