The Tax Court’s recent opinion in Roth v. Commissioner, T.C. Memo. 2017-248, raises interesting issues about the need for supervisor approval when the IRS asserts penalties. In 2007, the
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The Hazards of Trust Fund Recovery Penalties
The recent Tax Court decision in Woodley v. Commissioner, T.C. Memo. 2017-242, demonstrates the hazards of trust fund recovery penalties (TFRPs) for taxpayers. A TFRP is a penalty imposed
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Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized
We have all heard the old proverb “if it’s too good to be true, then it probably is.” In the tax world, this proverb might as well be referred to
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Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
The issue before the Tax Court in Huzella v. Commissioner, T.C. Memo. 2017-210, centered around a coin business on eBay, and whether the petitioner, Thomas Huzella, could substantiate his
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IRS Audits of Cannabis Companies and the Importance of Substantiation
Today, the Tax Court issued its opinion in Feinberg v. Commissioner, a case involving an ongoing and hard fought battle between the IRS and a medical marijuana dispensary, Total
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Conservation Easements: Easement Deed Fails to Satisfy Perpetuity Requirement
In Palmolive Building Investors, LLC v. Commissioner, 149 T.C. No. 18, the Tax Court denied a charitable contribution deduction of a donated façade easement because the easement deed failed
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Tax Court Denies Treaty Benefit to Canadian Post–Doctoral Fellow
In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation
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Tax Court Broadens Foreign Earned Income Exclusion
The Tax Court’s recent decision in Linde v. Commissioner, T.C. Memo. 2017-180, brought good news to taxpayers working outside the United States. In Linde, the Tax Court held
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Tax Court Issues Opinion Striking Down Captive Insurance Arrangement
The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from
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