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Business Expenses Tax Court

Rivkin Radler LLP

Tax Planning for Business Owners Who Shortchange Themselves

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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

Rivkin Radler LLP

The Closely Held Business and The Tax Gap

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Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...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

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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

Coblentz Patch Duffy & Bass

Distinguishing Investment and Business Expenses - Family Office Structuring After Lender

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

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Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses deficiencies for disallowed business expenses claimed by taxpayers, Mathew Craddock and Chasta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

Stikeman Elliott LLP

Dental Crowns and GST/HST Credits: A Dentist Wants to Have His Cake and Eat it Too

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In an informal procedure decision, Axelrod v. The King, rendered on December 12, 2022, the Tax Court of Canada dismissed the appeals of a dentist denying input tax credits (“ITCs”) claimed in connection with certain expenses...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

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

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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

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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

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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

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

Rivkin Radler LLP

Business Expenses Paid by Shareholder, But Whose Deduction Is It?

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Constructive Transfers- It is axiomatic that the tax treatment of interactions between a closely held business and its owners will generally be subject to heightened scrutiny by the IRS, and that the labels attached to such...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

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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

Freeman Law

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

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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

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

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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

Freeman Law

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

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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

Freeman Law

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

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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

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