On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner
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Tax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
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In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties. …
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Tax Court Holds IRS Complied with Supervisor Approval Requirement
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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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Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
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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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Tax Court Denies Treaty Benefit to Canadian Post–Doctoral Fellow
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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
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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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