Jason Freeman

Jason Freeman

Freeman Law

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Tax Court in Brief | Scheizer v. Comm’r | Charitable Contribution Substantiation and Reliance on Tax Professional

Tax Litigation: The Week of October 3rd, 2022, through October 7th, 2022 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 | Morrison, J. | Dkt. No. 22472-16...more

10/25/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Treasury Regulations

Tax Court in Brief | Sander v. Comm’r | Standing to Contest Deficiency of Another

Tax Litigation: The Week of October 3rd, 2022, through October 7th, 2022 Scheizer v. Comm’r, T.C. Memo. 2022-102 | October 6, 2022 | Lauber, J. | Dkt. No. 3679-18 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 |...more

10/24/2022 / Income Taxes , IRS , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Patitz v. Comm’r | Schedule A and Schedule C Itemized Deductions and Documentation Requirements

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Powell and Iakovenko v. Comm’r, T.C. Summary Opinion, 2022-19 | Sept. 26, 2022 | Copeland, J. | Docket No. 20268-19S Powell and Iakovenko v....more

10/19/2022 / Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Collins v. Comm’r | Innocent Spouse Requests a Refund for Which He Did Not Pay; Denied

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/19/2022 / Income Taxes , Innocent Spouse Exception , IRS , Joint Tax Returns , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Relief , Tax Returns

Tax Court in Brief | Powell v. Comm’r | IRS Forms vs. Statutes – Net Capital Loss Deduction

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/19/2022 / Capital Losses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Ashford v. Comm'r | Unreported Income, Additions to Tax, Frivolous Arguments, Taxable Income

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/18/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Powell and Iakovenko v. Comm’r | Schedule D to Form 1040 & Advance Premium Tax Credit

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/18/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Furrer v. Comm'r | Charitable Remainder Trusts; Non-Cash Charitable Contribution Substantiation; Taxability...

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/17/2022 / 501(c)(3) , Charitable Deductions , Income Taxes , IRS , Tax Court , Tax Exemptions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Vorreyer v. Comm’r | Thoma v. Comm’r | Dowson v. Comm’r | Deductibility of S Corp Expense Paid by Shareholder

Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Goddard v. Comm’r; Lee, Goddard, & Duffy, LLP v. Comm’r, T.C. Memo 2022-96| September 19, 2022 | Copeland, Judge | Dkt. No. 22334-17L, 23743-18L...more

10/14/2022 / Income Taxes , IRS , S-Corporation , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Goddard v. Comm'r | Collection Due Process, Penalties for Failure to Register a Tax Shelter

Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more

10/14/2022 / Income Taxes , IRS , Tax Court , Tax Debt , Tax Liability , Tax Liens , Tax Planning , Tax Returns , Tax Shelters

Tax Court in Brief | Estate of Clemons v. Comm’r | Dangers of FBAR, Accuracy-Related Penalties, and Foreign Assets

Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Degourville v. Comm’r, T.C. Memo. 2022-93 | September 12, 2022 | Wells, J. | Dkt. No. 4369-16 Fabian v. Comm’r, T.C. Memo 2022-94| September 13,...more

10/3/2022 / FBAR , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Degourville v. Comm’r | Earned Income Tax Credit, Head of Household Status, and “Badges of Fraud”

Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Fabian v. Comm’r, T.C. Memo 2022-94| September 13, 2022 | Halpern, Judge | Dkt. No. 25589-14 Estate of Clemons v. Comm’r, T.C. Memo. 2022-95|...more

10/3/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Fabian v. Comm’r | Fraudulent Returns, Constructive Receipt, and Guilty Plea | Don’t be Like Fabian

Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Degourville v. Comm’r, T.C. Memo. 2022-93 | September 12, 2022 | Wells, J. | Dkt. No. 4369-16 Estate of Clemons v. Comm’r, T.C. Memo. 2022-95|...more

10/3/2022 / Income Taxes , IRS , Joint Tax Returns , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Clarkson v. Comm’r | Frivolous Return Penalties and “Zero Returns”

Tax Litigation: The Week of September 5th, 2022, through September 9th, 2022 Clarkson v. Comm’r, T.C. Memo 2022-22| September 7, 2022 | Lauber, Judge | Dkt. No. 16804-21L...more

9/29/2022 / Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Standard of Review , Tax Court , Tax Liability , Tax Planning , Tax Returns

Country-by-Country Reporting

In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

9/27/2022 / BEPS , Country-by-Country , GAAP , Income Taxes , International Tax Issues , OECD , Tax Liability , Tax Planning , Tax Returns

International Tax Concepts: Dual-Status Taxpayers

A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

9/27/2022 / Corporate Taxes , Dual Citizenship , Income Taxes , International Tax Issues , IRS , Non-Resident Income Taxes , Tax Court , Tax Deductions , Tax Liability , Tax Returns

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

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

9/27/2022 / Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

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

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

9/26/2022 / Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Sek v. Comm’r | COBRA, Deficiency for Health Coverage Tax Credit, and Premium Assistance Tax Credit

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

9/23/2022 / COBRA , Employee Benefits , Health Insurance , Income Taxes , IRS , Tax Returns

Tax Court in Brief | Dern v. Comm’r | Direct Causation a Must to Exclude from Income Damages for Injury or Sickness, Section...

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

9/23/2022 / Income Taxes , IRS , Misclassification , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Remisovsky v. Comm’r | Reasonable Cause Exception to Additions to Tax

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....more

9/23/2022 / Burden of Proof , Income Taxes , IRS , Reasonable Cause Defense , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Pressman v. Comm’r | Deductibility of Home Mortgage Interest and Penalties

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 Domdom v. Comm’r, T.C. Summary Opinion...more

9/22/2022 / Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Mortgage Interest , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Domdom v. Comm’r | Foreign Earned Income and Tax Home for U.S. Income Tax

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

9/21/2022 / Foreign Earned Income , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties. The case arose in the context of a Liechtenstein...more

9/19/2022 / Federal Taxes , Filing Requirements , Foreign Trusts , Income Taxes , IRS , Required Forms , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Medtronic, Inc. v. Comm’r | Section 482, Comparable Uncontrolled Transaction, Comparable Profits Method

Tax Litigation: The Week of August 15th, 2022, through August 19th, 2022 Medtronic, Inc. v. Comm’r, T.C. Memo. 2022-84 | August 18, 2022 | Kerrigan, J. | Dkt. No. 6944-11. Short Summary: This opinion regards a transfer...more

8/22/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Section 482 , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Treasury Regulations

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