IRS, Tax Liability, Business Expenses

Hobby Loss Rules Revisited

Foster Garvey PC on 4/23/2025

With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Gregory v. Commissioner : A lesson in application of the ‘hobby loss’ rules

McAfee & Taft on 7/19/2023

Many of you are familiar with what are commonly referred to as the “hobby loss” rules. Section 183 of the Internal Revenue Code limits a taxpayer’s ability to deduct expenses associated with activities “not engaged in for...more

Tax Planning for Business Owners Who Shortchange Themselves

Rivkin Radler LLP on 6/6/2023

Something’s Wrong- Of late, a not insignificant number of the business owners with whom I’ve been working have raised some concern over whether they are financially prepared for the next stage of their lives. ...more

Tax Court in Brief | Moore v. Comm’r | Research Credit and Computation of Research Expenses under Section 41(a)

Freeman Law on 2/27/2023

Summary: Petitioner Gayla Moore was the sole owner of Nevco, Inc. (Nevco), a subchapter S corporation, during the tax years in issue (2014 and 2015). Nevco claimed the section 411 credit for increasing research activities...more

Tax Court in Brief | Avery v. Comm’r | Collection Due Process and a Lawyer’s Race Car Business Expense Deductions

Freeman Law on 2/27/2023

Summary: Since 1982, James William Avery (Avery) was a practicing lawyer, specializing in personal injury law as a solo practitioner primarily in Denver, Colorado for the period 2008–2013 but also some in Indiana during...more

Distinguishing Investment and Business Expenses - Family Office Structuring After Lender

Coblentz Patch Duffy & Bass on 2/6/2023

Structuring a family’s investment activities can be complex. Across assets, activities, relationships and the particular circumstances of each family member-investor, a family office will typically provide a spectrum of...more

Tax Court in Brief | Craddock v. Comm'r | Deficiency for Disallowed Business and Travel Expenses

Freeman Law on 2/6/2023

Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses deficiencies for disallowed business expenses claimed by taxpayers, Mathew Craddock and Chasta Craddock. Mr. Craddock was employed...more

Tax Court in Brief | Simpson v. Comm’r | Deficiencies for Unsubstantiated Expenses; Accountable Reimbursement Plans; and Basis in...

Freeman Law on 1/16/2023

Kyle Simpson and Christen Simpson, husband and wife (the Simpsons), were equal shareholders in a wholly owned S corporation (S Corp). Through S Corp, Mr. Simpson developed open-source software. He was also employed by three...more

Trump’s Returns and Congress – Lessons, Next Steps?

Rivkin Radler LLP on 1/5/2023

Last Friday, December 30, 2022, during the final hours of the 117th Session of Congress, the House Ways and Means Committee – through which all tax legislation passes – released redacted versions of six years of Mr. Trump’s...more

Tax Court in Brief | Ismail v. Comm’r | Foreign LLC for U.S. tax purposes; Substantiation of Schedule C Expenses; Section 274

Freeman Law on 1/3/2023

Short Summary: The case discusses the tax classification of a foreign corporation for U.S. tax purposes and the substantiation of various business expenses such as vehicle, travel, and meals and entertainment expenses....more

Tax Court in Brief | Ayria v. Comm’r | Substantiation for Schedule C Deductions (lodging, vehicle, entertainment, gifts, dry...

Freeman Law on 12/27/2022

Ayria v Commissioner, T.C. Memo. 2022-123 | December 19, 2022 | Lauber, J.| Dkt. No. 13745-20 - Short Summary: This case involves the disallowance of taxpayer’s business expenses reported on Schedule C, Profit or Loss...more

Tax Court in Brief | Palmarini Inc. v. Commissioner, Palmarini v. Commissioner | Recordkeeping and Constructive Dividends

Freeman Law on 12/16/2022

The Tax Court in Brief – December 12th – December 16th, 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

Transacting With One’s Business – Keep It Arm’s Length

Rivkin Radler LLP on 12/16/2022

Don’t Be Unreasonable- Much has been written of late regarding the payment by a business of various personal expenses incurred by its owner or certain key employees. The payment of an owner’s personal expenses appears to...more

Tax Court in Brief | Hoakison v. Comm’r | Schedule F Farming Expense Deductions and Deficiencies Relating to Same

Freeman Law on 12/12/2022

Hoakison v. Comm’r, T.C. Memo. 2022-117| December 5, 2022 | Paris, J. | Dkt. No. 16577-17 Short Summary: Mr. and Mrs. Hoakison (collectively, the “Hoakisons”) are long-time farmers. They own real estate used for farming and...more

Tax Court in Brief | Butterfield v. Comm’r | Travel Reimbursements and Itemized Deductions

Freeman Law on 9/27/2022

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more

Tax Court in Brief | Luna v. Comm’r | Disallowance of Itemized Business Deductions and Lack of Substantiation

Freeman Law on 9/26/2022

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more

Tax Court in Brief | Kinney v. Commissioner | Schedule C Deductions Legal Fees, Insurance, Car and Travel Expenses

Freeman Law on 8/3/2022

Tax Litigation: The Week of July 25th, 2022, through July 29th, 2022 Elstein v. Comm’r, T.C. Summary Opinion 2022-14 | July 18, 2022 | Panuthos, J. | Dkt. No. 18272-17S Hall v Commissioner, T.C. Memo. 2022-82 | July 28, 2022...more

Tax Court in Brief | Gonzalez v. Commissioner | Proving Up Business Expenses

Freeman Law on 7/29/2022

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

Freeman Law on 7/18/2022

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

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

Freeman Law on 6/23/2022

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

Freeman Law on 6/22/2022

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

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

Freeman Law on 6/8/2022

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

Freeman Law on 5/31/2022

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

Freeman Law on 5/6/2022

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

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

Freeman Law on 4/14/2022

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

Internal Revenue Service › Tax Liability › Business Expenses

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