Income Taxes, Tax Liability, Tax Deductions

Liberty Global Appeals Economic Substance Doctrine Ruling

Cadwalader, Wickersham & Taft LLP on 9/3/2024

In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part VII –...

Foster Garvey PC on 6/6/2024

In the S corporation arena, tax advisors generally do not focus much attention on unreasonable compensation. As we delve into the issue in this Part VII of my multi-part series on Subchapter S, it will become apparent that...more

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on 3/7/2024

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

[Webinar] Tax Considerations for Foreign Rental Property: Holding Structures, Reporting Rental Income and Expenses, FTCs - March...

Strafford on 2/22/2024

This course will discuss the considerations and caveats of U.S. residents owning foreign rental property. Our seasoned panel of international tax experts will explore U.S. and foreign holding structures, residential and...more

Court Rules on Tax Treatment of Hotel Rewards Program Fund

Miller Canfield on 10/20/2023

The recent Tax Court opinion in Hyatt Hotels Corporation v. Commissioner of Internal Revenue informs a federal income taxpayer about its tax responsibility for funds for a guest reward program: when the taxpayer will be...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

Estate Tax Panning for Married Couples: Using Estate Tax Exemptions

Ward and Smith, P.A. on 6/23/2023

A primary goal of most married couples when contemplating basic estate planning documents is to ensure that the surviving spouse, and commonly, the couple's children and grandchildren, are supported financially. Permissible...more

Tax Tips for New College Graduates

Bowditch & Dewey on 6/22/2023

As new college graduates cross the stage to receive their diplomas, many will also be heading to their first full-time jobs. There are some tax tips new graduates can implement early on that will help with savings in the long...more

Tax Court in Brief | Estate of Hoenshied v. Commissioner | Anticipatory Assignment of Income, Charitable Contribution Deduction,...

Freeman Law on 4/10/2023

Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more

Taxation and Representation, March 28, 2023

Brownstein Hyatt Farber Schreck on 4/4/2023

Treasury Department and IRS Release Preliminary Guidance on Semiconductor Tax Credit. On March 23, the Treasury Department and IRS published proposed regulations for implementing the new section 48D advanced manufacturing...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

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of...

Freeman Law on 2/20/2023

Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...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 | Johnson v. Comm'r | Section 179D Energy Efficient Building Property Deduction

Freeman Law on 1/30/2023

Summary: In this 32-page, consolidated opinion, the Tax Court addresses deficiencies from disallowance of a 26 U.S.C. § 179D energy efficient building property deduction claimed by Edwards 4 Engineering, Inc. (Edwards), an S...more

Tax Court in Brief | Aragoni v. Comm'r | Disallowance of Deduction of Ex-Spouse’s Attorney Fees as Alimony

Freeman Law on 1/30/2023

Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an alimony deduction claimed by taxpayer Terrence Aragoni. Aragoni divorced his wife. By court order, Aragoni was ordered to pay $9,146...more

Tax Court in Brief | Lim v. Comm'r | Disallowance of Charitable Contribution Deduction for Lack of Qualified Appraisal; Reasonable...

Freeman Law on 1/30/2023

Summary: This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more

Tax Court in Brief | Shilgevorkyan v. Comm'r | Deficiency for Disallowed Mortgage Interest Deduction; Qualified Residence Interest

Freeman Law on 1/30/2023

Summary: This is a deficiency case involving taxpayer Hrach Shilgevorkyan (Petitioner) and the IRS’s disallowance of a mortgage interest deduction for tax year 2012. In 2005 Edvard, Petitioner’s brother, purchased the...more

Federal and California Taxpayer Relief: Reprieve From Wet Winter Weather

Farella Braun + Martel LLP on 1/25/2023

2023 started California off with weather that escapes recent memory. Rain, snow, and surf seemed unrelenting for the first two weeks of January. While this spell of winter storms has brought snow to our slopes and refilled...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

Taxation & Representation, Jan. 3, 2023

Brownstein Hyatt Farber Schreck on 1/6/2023

Legislative Lowdown - Lawmakers Look to 2023 for Tax Priorities Following Omnibus Passage. On Dec. 29, President Joe Biden signed the nearly $1.7 trillion Consolidated Appropriations Act of 2022 into law, funding the...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 | Brooks v. Comm’r | Charitable Contribution Deductions for Conservation Easement; Contemporaneous Written...

Freeman Law on 12/23/2022

Tax Litigation: The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...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

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

Income Taxes › Tax Liability › Tax Deductions

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