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DLA Piper

Deductibility of Consultancy Fees Upheld by Supreme Administrative Court

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On 26 May 2025, the Swedish Supreme Administrative Court ruled in favour of OneMed Sverige AB regarding the deductibility of consultancy fees and input VAT. OneMed had reimbursed its parent company for consulting services...more

Morgan Lewis

Düsseldorf Fiscal Court: Legal and Consulting Fees for Sale of Second-Tier Subsidiary Fully Deductible Irrespective of an Existing...

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In its decision dated February 26, 2025 (7 K 1811/21 K), the Düsseldorf Fiscal Court concluded that legal and consulting fees incurred by the indirect sale of a second-tier subsidiary by the subsidiary are deductible business...more

Foster Garvey PC

Hobby Loss Rules Revisited

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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

McGlinchey Stafford

Paid or Incurred: Marijuana Rescheduling, Taxes, and Section 280E

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The cannabis industry knows well the economic burden imposed by Section 280E of the Internal Revenue Code of 1986 (Code). It substantially increases the cost of doing business because it disallows deductions for expenses...more

Foodman CPAs & Advisors

¿Es Un Hobby O Negocio?

Los contribuyentes pueden enfrentarse a la pregunta: “¿Es un hobby o negocio?”. El IRS afirma que: “a veces la línea entre tener un hobby y administrar un negocio puede ser confusa, pero conocer la diferencia es importante...more

Foodman CPAs & Advisors

Is It A Hobby Or Business?

Taxpayers may be faced with the question: “Is it a hobby or business?” The IRS states that: “sometimes the line between having a hobby and running a business can be confusing, but knowing the difference is important because...more

Foodman CPAs & Advisors

Jets Corporativos Y El IRS

El 2/21/24, el IRS anunció que comenzará a auditar el uso de aviones corporativos como parte de su esfuerzo más amplio para asegurar que los grupos de altos ingresos “no pasen desapercibidos” en sus responsabilidades...more

Foodman CPAs & Advisors

Corporate Jets And The IRS

On 2/21/24, the IRS announced that it will begin auditing corporate jet usage as part of its larger effort to ensure high-income groups “don’t fly under the radar” on tax responsibilities. IRS Commissioner Danny Werfel...more

McAfee & Taft

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

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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

Freeman Law

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

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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

Freeman Law

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

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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

Freeman Law

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

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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

Freeman Law

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

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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

Freeman Law

Tax Court in Brief | Wondries v. Comm’r | Deficiencies for Deduction of Farm and Ranch Expenses; Hobby or Activity Engaged in For...

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Summary: Paul Wondries and Patricia Wondries (the Wondries) sought relief from the Tax Court to review the IRS’s determinations of deficiencies and accuracy-related penalties arising mainly from deductions for expenses...more

Freeman Law

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

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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

Freeman Law

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

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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

Freeman Law

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

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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

Stinson LLP

Owners of a Corporation Pay the Corporation's Expenses; Can Such Expenses be Deducted by the Owners?

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As a general rule, a corporation is considered a separate entity from its owner(s). There are a few cases in which a corporate entity is disregarded as an entity separate from its owners, such as when a corporation is set up...more

Freeman Law

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

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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

Freeman Law

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

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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

Freeman Law

Tax Court in Brief | Eze v. Commissioner | Schedules C and C2 Business Expense Deductions of a Sole Proprietorship

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Tax Litigation: The Week of August 1st, 2022, through August 5th, 2022 Whistleblower 769-16W v. Comm’r, 159 T.C. No. 2 | August 4, 2022 | Toro, J. | Dkt. No. 769-16W ...more

Freeman Law

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

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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

Freeman Law

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

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Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Pettennude v. Comm’r, T.C. Memo. 2022-79 | July 18, 2022 | Buch, J. | Dkt. No. 636-21L Soler v. Comm’r, T.C. Memo. 2022-78 | July 18, 2022 | Marvel, J. |...more

Freeman Law

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

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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

Freeman Law

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

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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

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