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Tax Court in Brief | Rau v. Comm’r | Business Expense and Non-cash Charitable Contribution Deductions

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

Tax Court in Brief | Hacker v. Com’r | Constructive Dividends, Unexplained Deposits, and Corporate Spending

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No. 23074-19S Cosio v. Comm’r, T.C. Memo. 2022-18 | March 9, 2022 | Weiler, J. | Dkt. No....more

Tax Court in Brief | Sherwin Community Painters Inc. v. Comm’r | Business Expenses and Constructive Dividends

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 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

Tax Court in Brief | Clary Hood, Inc. v. Comm’r | “Reasonable Compensation” and Disguised Dividend

Tax Litigation: The Week of February 28, 2022, through March 4, 2022 Corning Place Ohio, LLC v. Comm’r, T.C. Memo. 2022-12 | February 28, 2022| Lauber, J. | Dkt. No. 12428-20 Lewis v. Comm’r, 158 T.C. No. 3 | March 1, 2022 |...more

Grantor Trusts

Under the Internal Revenue Code’s “grantor trust” rules, the grantor of a trust may be treated as the “owner” of all or part of the trust.  As such, the grantor is taxed on the trust’s income and reports its deductions...more

Tax Court in Brief | Estate of Kazmi v. Commissioner | Trust Fund Penalties and CDP Hearings

Tax Litigation:  The Week of February 28, 2022, through March 4, 2022 - Estate of Levine v. Comm’r, 158 T.C. No. 2 | February 28, 2022 | Holmes, J. | Dkt. No. 13370-13 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28,...more

Tax Court in Brief | Hoops, LP v. Commissioner: Deductibility of Deferred Compensation

Tax Litigation: The Week of February 21, 2022, through February 25, 2022 - Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23, 2022 | Gale, J. | Dkt. No. 10406-17 - Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23,...more

Tax Court in Brief | Hicks v. Commissioner: Dependency Deductions

Tax Litigation: The Week of February 21, 2022, through February 25, 2022 Hoops, LP v. Comm’r, T.C. Memo. 2022-9 | February 23, 2022 | Nega, J. | Dkt. No. 11308-18 Hicks v. Comm’r, T.C. Memo. 2022-10 | February 23,...more

Tax Court in Brief – Ola-Buraimo v. Comm’r

The Tax Court in Brief February 14 – February 18, 2022 - Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Tax Court in Brief – Harwood v. Commissioner

The Tax Court in Brief February 14 – February 18, 2022 - Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Tax Court in Brief – Sonntag v. Commissioner

The Tax Court in Brief February 14 – February 18, 2022 - Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

The Tax Court in Brief - December 2021 #3

Tax Litigation: The Week of December 19 – December 25, 2021 - William R. Huff and Cathy Markey Huff, v. Comm’r, T.C. Memorandum 2021-140| December 21, 2021 | Urda, J. | Dkt. No. 22604-17. Short Summary:  The main issue...more

The Claim-Of-Right Deduction: Grantor Trust’s Prohibited Sale of Restricted Stock Did Not Give Rise to Relief Under Section 1341

In the recent case of Heiting v. United States, the Seventh Circuit Court of Appeals denied the taxpayer’s claim-of-right deduction pursuant to Internal Revenue Code section 1341.  The case stemmed from the taxpayer’s attempt...more

The Tax Court in Brief - December 2021 #2

Tax Litigation: The Week of December 13 – December 18, 2021 - Antonyan, et. al. v. Comm’r, TC Memo. 2021-138 | December 13, 2021 | Nega, J. | Dkt. No. 13741-18 - Short Summary: In 2012 or 2013, Mr. Antonyan purchased...more

The Claim-of-Right Doctrine & Section 1341

The U.S. Congress passed the Tax Cuts and Jobs Act (TCJA) in late 2017, substantially overhauling the Internal Revenue Code of 1986. The TCJA highlighted the importance of several often-overlooked provisions in the Tax Code....more

The Tax Court in Brief - October 2021

Tax Litigation: The Week of September 27 – October 1, 2021 - Whistleblower 14377-16W v. Comm’r, T.C. Memo. 2021-113 | September 27, 2021 | Halpern, J. | Dkt. No. 14377-16W - Short Summary: The whistleblower brought a...more

The Tax Court in Brief - September 2021 #4

Tax Court Litigation: The Week of September 20 – September 24, 2021 - Daniel Omar Parker and Chantrell Antoine Parker v. Comm’r, No. 13231-19, T.C. Memo 2021-111 | September 23, 2021 | Lauber | Dkt. No. 13231-19 -...more

The Tax Court in Brief - September 2021 #2

Tax Court Cases: The Week of August 30 – September 3, 2021 - Karson C. Kaebel v. Comm’r, No. 16171-18P, T.C. Memo 2021-109 | September 9, 2021 | Halpern | Dkt. No. 16171-18P - Tax Dispute Short Summary: This case focuses on...more

Estimating Tax Deductions: The Cohan Rule

The Cohan Rule: Tax Deductions with Incomplete Records - The “Cohan rule” is derived from the Second Circuit’s 1930 decision, Cohan v. Commissioner, which allowed the taxpayer to approximate travel and entertainment...more

The Tax Court in Brief - September 2021

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. Tax Court: The Week of August 30 – September 3, 2021 - Tax Court...more

The Tax Court in Brief - August 2021 #4

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more

The Tax Court in Brief - August 2021 #3

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 9 – August 13, 2021 - Manuelito B. Rodriguez &...more

Section 280E and The Taxation of Cannabis Businesses

Section 280E of the Internal Revenue Code prohibits taxpayers who are engaged in the business of trafficking certain controlled substances (including, most notably, marijuana) from deducting typical business expenses...more

The IRS’s Dirty Dozen Tax Schemes—Installment Four

The IRS recently concluded its 2021 four-part series of the “Dirty Dozen” tax-related scams. The fourth installment focuses on what the Service refers to as “schemes peddled by tax promoters, including syndicated...more

The Tax Court in Brief - May 2021 #2

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. ...more

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