Below is a list of the 2023 cases of the U.S. Tax Court. We've kept the key word list short to make searches easy. Use the "find-in-page" or "find" feature of your browser (CTRL-F) to search this list. Be sure to try variations of keywords such as "activities" as well as "activity"; "depreciation" as well as "depreciate". Please note that the mention of an issue does not in any way imply the outcome. For example, if "fraud penalty" is mentioned, that only means the fraud penalty was an issue, not that it was imposed or rejected by the Court. Hypenation has become an art form. Try searches with and without. The majority of cases mention Sec. 7491 (Burden of Proof); we have not listed it unless it was a significant issue.

NOTE--The U.S. Tax Court has significantly revising its system of presenting cases and other information. Our old links (in year 2020 and prior) no longer work. However, you may search the U.S. Tax Court website at dawson.ustaxcourt.gov/ from the options Case Order Opinion select Opinion and search there by case/petitioner's name or by date or date range. You can search for cases as far back as May 1, 1986.

For a similar synopsis of cases for prior years, go to:

Tax Court Cases--2022
Tax Court Cases--2021
Tax Court Cases--2020
Tax Court Cases--2019
Tax Court Cases--2018
Tax Court Cases--2017
Tax Court Cases--2016
Tax Court Cases--2015
Tax Court Cases--2014
Tax Court Cases--2013
Tax Court Cases--2012
Tax Court Cases--2011
Tax Court Cases--2010
Tax Court Cases--2009
Tax Court Cases--2008
Tax Court Cases--2007
Tax Court Cases--2006
Tax Court Cases--2005
Tax Court Cases--2004

Tax Court Cases

Madiodio Sall (161 T.C. No. 13) Sec. 7451; Tax Court petitions; due date of petition; day after Thanksgiving; deadline extended.
Soroban Capital Partners LP, Soroban Capital Partners GP LLC, Tax Matters Partner (161 T.C. No. 12) Sec. 1402; 6221; self-employment tax definitions; determination at partnership level; net earnings from self-employment; limited partner; functions and roles of limited partner; partnership item.
YA Global Investments, LP f/k/a Cornell Capital Partners, LP, Yorkville Advisors, GP LLC, Tax Matters Partner and YA Global Investments, LP f/k/a Cornell Capital Partners, LP, Yorkville Advisors, LLC, Tax Matters Partner;YA Global Investments, LP, Yorkville Advisors GP, LLC, Tax Matters Partner (161 T.C. No. 11) Sec. 475; 864; 1446; mark-to-market accounting method for securities dealers; definitions and special rules; withholding tax on foreign partners' share of effectively connected income; U.S. trade or business; required withholding.
Liberty Global, Inc. (161 T.C. No. 10) Sec. 904; 1001; 1248; limitation on foreign tax credit; amount of and recognitiion of gain or loss; gains from sales of stock in certain foreign corporations; overall foreign loss; foreign loss recapture; recharacterization of some foreign source income as U.S. source; gain from foreign source; Sec. 904 does not override recognition provisions.
Estate Of Andrew J. Mckelvey, Deceased, Bradford G. Peters, Executor (161 T.C. No. 9); Sec. 1001; 1234A; amount and recognition of gain or loss; gains and losses from certain terminations; variable prepaid forward contracts; VPFC; short-term capital gains;.
Tiffany Lashun Sanders (161 T.C. No. 8) Sec. 6213; Tax Court petitions; 90-day deadline to file petition; jurisdiction; dismissal of case.
Wolfgang Frederick Kraske 161 T.C. No. 7) Sec. 6662; accuracy related penalty; supervisory approval of penalty by tax compliance officer's supervisor.
Estate of James E. Caan, Deceased, Jacaan Administrative Trust, Scott Caan, Trustee, Special Administrator (161 T.C. No. 6) Sec. 408; Individual Retirement Accounts; distribution for failure to follow bank rules; failure to provide year-end fair market value; change of character of property when recontributed.
Whistleblower 8391-18W (161 T.C. No. 5) Sec. 7623; expenses of detection of underpayment and fraud; supplemental information to an open audit; interest on award during appeal.
Organic Cannabis Foundation, LLC (161 T.C. No. 4) Sec. 6320; hearing on filing lien notice; collection due process; CDP; request for CDP hearing outside 30-day period; authority by Appeals to hold hearings on late-filed requests.
Piper Trucking and Leasing, LLC (161 T.C. No. 3) Sec. 6721; 6741; failure to file correct information returns; procedural requirements; W-2 statements not filed; Combined Annujal Wage Reporting; CAWR; failure to obtain supervisory approval of penalty; approval not necessary for CAWR penalty.
Zola Jane Pugh (161 T.C. No. 2) Sec. 7345; revocation or denial of passport of certain tax delinquencies; seriously delinquent tax debt; taxpayer's motion to dismiss.
Joseph E. Abe, DDS, Inc. (161 T.C. No. 1) Sec. 7476; declaratory judgments relating to qualification of certain retirement plans; petition dismissed; qualifications of plan revoked by IRS

Antawn Jamal Sanders (160 T.C. No. 16) Sec. 6213; 7451; petitions to Tax Court; petitions; electronic filing of petition; received by Tax Court 11 seconds after midnight; untimely petition.
Josefa Castillo (160 T.C. No. 15) Sec. 6330; 7430; hearing before levy; recovery of litigation costs;; collection due process; CDP; jurisdiction of Tax Court; late filing of Tax Court petition; decision by U.S. Supreme Court in Boechler, P.C.; concession by IRS; decision confined to litigation costs.
Jeremy Berenblatt (160 T.C. No. 14) Sec. 7623; expenses of detection of underpayment and fraud; motion to compel discovery; prior knowledge of information; administrative record incomlete.
Prince Amun-Ra Hotep Ankh Meduty (!60 T.C. No. 13) Sec. 7345; revocation or denial of passport; seriously deliquent tax debt; debt legally enforceable; levy made; jurisdiction.
(160 T.C. No. 12) Sec. 41; 45C; credit for increasing research activities; base period expenses; clinical testing expenses for certain drugs; overstatment of research credit by improperly excluding from computations expenses treated as qualified clinical testing expenses.
Growmark, Inc. and Subsidiaries (160 T.C. No. 11) Sec. 6426; credit for alcohol fuel, biodiesel; credit against tax precludes cost of goods sold deduction; actual excise tax expense.
Roy A. Nutt and Bonnie W. Nutt (160 T.C. No. 10) Sec. 6213; 7502; petition to Tax Court; timely mailing as timely filing; petition filed late; eastern time zone controls filing time.
Gladys L. Gerhardt, et al (160 T.C. No. 9) Sec. 664; 1031; 1245; 6662; charitable remainder trusts; like-kind exchange; gain from disposition of depreciable property; accuracy-related penalty; CRATS; annuity payments from charitable remainder annuity trusts taxable as ordinary income; gain not recognized on transfer to trust; gain on Sec. 1245 property transferred in like-kind exchange.
David W. Tice (160 T.C. No. 8) Sec. 932; 6501; U.S. and Virgin Islands income taxes; limitations on assessment and collection; residency in Virgin Islands; statute of limitations not triggered unless bona fide resident.
Srbislav B. Stanojevich (160 T.C. No. 7) Sec. 6702; penalty for frivolous returns; trust return; trustee liable.
Alon Farhly (160 T.C. No. 6) Sec. 6038; information reporting on foreign corporations and partnerships; IRS authority to assess penalties for failure to file Form 5471.
Thomas Shands (160 T.C. No. 5) Sec. 7623; expenses of detection of underpayment and fraud; Tax Court jurisdiction; nondiscretionary award; Offshore Voluntary Disclosure Initiative; OVDI; administrative or judicial action.
Sydney Ann Chaney Thomas (160 T.C. No. 4) Sec. 6015; 7345; innocent spouse relief; revocation or denial of passport; personal blog of individual introduced in evidence; newly discovered evidence; serious tax debt; Tax Court jurisdiction.
3M Comppany and Subsidiaries (160 T.C. No. 3) Sec. 402; allocation of income and deductions among taxpayers; arm's length compensation a Brazilian subsidiary should have; transfer pricing rules; intellectual property; foreign legal restrictions.
Michael Johnson and Cynthia Johnson, et al. (160 T.C. No. 2) Sec. 179D; energy efficient commercial buildings deduction; deduction limited to installation costs.
Blake M. Adams (160 T.C. No. 1) Sec. 7345; revocation or denial of passport; jurisdiction to review underlying liability; ability to rule on constitutionality.

Memorandum Decisions

David Villa and Juana M. Villa (T.C. Memo. 2023-155) Sec. 61; 162; 6662; gross income definition; business expenses; accuracy-related penalty; support for cash payments; cost of goods sold estimated; recordkeeping substantiatiion.
Daniel Olin Nye (T.C. Memo. 2023-154) Sec. 7345; revocation or denial of passport for certain tax delinquencies; debt properly assessed; notice of federal tax lien filed.
Whistleblower 972-17W (T.C. Memo. 2023-152) Sec. 7623; expenses of detection of underpayment and fraud; whistleblower's information did not result in the additional taxes and penalties.
Dziuy Nguyen and Jessica Thai (T.C. Memo. 2023-151) Sec. 6213; 7502; petition to Tax Court; timely mailing as timely filing; timely mailing rule not available; FedEx ground used for filing.
Victor Attisha and Josephine Attisha(T.C. Memo. 2023-150) Sec. 446; 6001; 6662; methods of accounting; requirement to maintain books and records; accuracy-related penalty; unreported income; income from marijuana sales; reconstruction of income; evidentiary requirement.
John Thomas Minemyer (T.C. Memo. 2023-149) Sec. 6663; civil fraud penalty; substantially underreported income; badges of fraud; creation of foreign entities; participation in illegal activities.
Edward Francis Bachner, IV and Rebecca Gay Bachner (T.C. Memo. 2023-148); Sec. 6663; fraud penalty; fake W-2; badges of fraud.
Paul C. Robinson (T.C. Memo. 2023-147) Sec. 6662; 6751; accuracy-related penalty; procedural requirements; substantial authority for position; position disclosed on return; argument not in brief; approval of penalties proper.
Charles G. Berwind Trust For David M. Berwind, David M. Berwind, D. Michael Berwind, JR.; Gail B. Warden, Linda B. Shappy and Valerie L. Pawson, Trustees, et al. (T.C. Memo. 2023-146) Sec. 483; interest on certain deferred payments; year of transaction; sale or exchange determined by state business corporation law; merger of corporations Warner Enterprises (T.C. Memo. 2023-145) Sec. 6212; 6330; notice of deficiency; hearing before levy; collection due process; CDP; notice of deficiency and demand for payment verified as mailed; last known address.
Michael B. Shapiro (T.C. Memo. 2023-144) Sec. 6330; 6651; 6654; hearing before levy; failure to file or pay; failure to pay estimated tax; collection due process; CDP; failure to use ordinary care in filing returns.
Harman Road Property, LLC, Capital Conservation Partners II, LLC, Tax Matters Partner (T.C. Memo. 2023-143) Sec. 6227; Partnership's Administrative Adjustment Request; Administrative Adjust Request; AAR; FPAA.
Luminita Roman; Gabriel L. Roman (T.C. Memo. 2023-142) Sec. 61; 104; 6651; 6662; gross income definition; damage awards and sick pay; failure to file or pay; accuracy-related penalty; settlement of suit not related to physical injury or sickness; examination of language of settlement agreement; advice of professional; proof of advice; reliance on advice.
Danielle Monique Scott (T.C. Memo. 2023-141) Sec. 61; 72; gross income definition; distributions from pension plans; unreported income; age 59-1/2 penalty; failure to prove age.
Kunjlata J. Jadhav and Jalandar Y. Jadhav (T.C. Memo. 2023-140) Sec. 162; 274; 6662; business expenses; business expense substantiation; accuracy-0related penalty; employer-employee relationship with sons work; contribution to sons' 401(k) accounts; history of employer-employee relationship.
Allen R. Davison and Sharon L. Davison (T.C. Memo. 2023-139) Sec. 172; 6330; net operating loss; hearing before levy; NOL; collection due process; CDP; substantiation of losses; failure to cooperate with IRS; failure to provide financial information to determine collection potential; lien and levy were appropriate.
George E. Kosmides (T.C. Memo. 2023-138) Sec. 6330; hearing before levy; collection due process; CDP; partial payment installment agreement rejected; PPIA; compliance with guidelines.
Don L. Rockafellor and Kathleen M. Rockafellor (T.C. Memo. 2023-137) Sec. 6330; 6694; hearing before levy; understatement of taxpayer's liability by return preparer; collection due process; CDP; decisions by Tax Court; failure to submit financial information; failure to provide collection alternatives; Tax Court jurisdiction.
Rita Renee Pilate (T.C. Memo. 2023-136) Sec. 6330; hearing before levy; collection due process; CDP; income not reported; denial of collection alternative; challenge to underlying liability.
The Coca-Cola Company and Subsidiaries (T.C. Memo. 2023-135) Sec. 482; allocation of income and deductions among taxpayers; arm's-length companesation; licensing of intangibles; foreign legal restrictions; royalties paid by Brazilian affiliate.
Champions Retreat Golf Founders, LLC, Riverwood Land, LLC, Tax Matters Partner (T.C. Memo. 2023-134) Sec. 7430; recovery of litigation costs; prevailing party; IRS position was substantially justified.
Nathaniel A. Carter and Stella C. Carter v. Commissioner; Ralph G. Evans (T.C. Memo. 2023-133) Sec. 170; 6662; charitable contributions; accuracy-related penalty; conservation easement; Baseline Documentation; donor reserved specified rights under approval by donee; penalty for gross valuation misstatement.
Lior Blas; Leo Blas (T.C. Memo. 2023-132) Sec. 36B; 6330; advanced premium tax credit; hearing before levy; income exceeded threshold for claiming credit; 400 percent of poverty level; collection due process; CDP; increase in income during the year.
Nicole Diane Henaire (T.C. Memo. 2023-131) Sec. 119; 911; 6103; 7121; 6662; 6751; meals and lodging for convenience of employer; foreign earned income exclusion; confidentiality of returns; closing agreements; accuracy-related penlty; procedural requirements; waiver of election under Sec. 911 with employer; reason to set aside agreement; proof employer provided lodging for its convenience or lodging on employer's premises.
Kevin F. Long (T.C. Memo. 2023-130) Sec. 6320; 6330; hearing filing lien notice; hearing before levy; collection due process; CDP; abrupt ending of CDP hearing; request for collection alternatives; abuse of discretiion; cooperation by taxpayer.
Mill Road 36 Henry, LLC, MR36 Manager, LLC, Tax Matters Partner (T.C. Memo. 2023-129) Sec. 170; 6662; charitable contributions; accuracy-related penalty; qualified conservation easement; qualified appraiser; contribution limited to basis in land.
Wolfgang Frederick Kraske (T.C. Memo. 2023-128) Sec. 162; 183; 280A; 6662; business expenses; not-for-profit activities; home office deduction; accuracy-related penalty; businesslike manner; recordkeeping; lack of revenue; factors weighed.
Alan Michael Berkun (T.C. Memo. 2023-127) Sec. 6103; disclosure of return information; motion to compel production of documents; disclosure of grand jury information; third party return information.
Stephen R. Kelley and Isabelle Kelley (T.C. Memo. 2023-126) Sec. 61; 6662; gross income definition; accuracy-related penalty; failure to report wage income reported on W-2; claim reported wages not income; validity of the notice of deficiency; AUR; au;tomated undereporter program.
Martin G. Plotkin (T.C. Memo. 2023-125) Sec. 6330; hearing before levy; collection due process; CDP; balance of efficient collection with intrusive action; failure to supply requested financial information.
Abdul Khaliq Mustafa Muhammad T.C. Memo. 2023-124) Sec. 446; 6663; methods of accounting; civil fraud penalty; bank deposits method; unreported income; deemed admission; badges of fraud; no summary judgment on fraud penalties.
Eric Wilfred Olson (T.C. Memo. 2023-123) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; CDP; review by Independent Office of Appeals; no contest of unerlying liabilities; Tax Court not consider underlying liabilities.
Hyatt Hotels Corporation and Subsidiaries (T.C. Memo. 2023-122) Sec. 61; 451; 481; gross income definition; taxable year of inclusion; adjustments for changes in method of accounting; revenue from customer rewards program; control of income; trust fund doctrine; beneficial economic interest.
John Peter Zaimes (T.C. Memo. 2023-121) Sec. 6651; 7502; failure to timely file or pay; timely mailing as timely filing; failure to prove return mailed; reasonable cause for failing to make payment.
Joey R. Aiken and Melissa Dawn Aiken (T.C. Memo. 2023-120) Sec. 6330; hearing before levy; collection due process; CDP; failure by taxpayer to provide financial information for collection alternatives; failure to attend telephone conferences.
Farid Rafiee and Misuk P. Rafiee> (T.C. Memo. 2023-119) Sec. 6330; hearing before levy; collection due process; CDP; rejection of installment agreement; not in compliance with return filings and estimated tax obligations; failure by IRS to offer face-to-face hearing; balance of need for efficient tax collection with taxpayers' concern.
Joseph Michael Balint (T.C. Memo. 2023-118) Sec. 61; 72; 408; 6330; gross income definition; distributions from pension plans; IRA distributions; incarceration; wife as POA; wife's withdrawal of funds; no economic benefit to taxpayer; wife as beneficiary to IRA.
Sarah S. Onan (T.C. Memo. 2023-117) Sec. 6015; 6321; innocent spouse relief; lien for taxes; lien on residence.
John R. Johnson and Estate of Judith E. Johnson, Deceased, John R. Johnson, Personal Representative (T.C. Memo. 2023-116) Sec. 6662; 6664; accuracy-related penalty; reasonable cause; unable to show reasonable cause for penalty abatement; reliance on CPA; no evidence CPA advised their position; taxpayer's testimony wasn't credible.
Michael R. Stevenson (T.C. Memo. 2023-115) Sec. 6330; hearing before levy; collection due process; CDP; failure to meet estimated tax obligations; collection alternative denied.
Short stop Electric, Inc. (T.C. Memo. 2023-114) Sec. 162; 172; 179; 274; 6662; business deductions, net operating loss, expensing assets; business expense substantiation; accuracy-related penalty; interest deductiion; bona-fide loan; payments deemed capital contributions; net operating loss absorbed in prior years; expensing of certain assets denied because they were not used in the business.
William H. Evenhouse and Nelle L. Evenhouse (T.C. Memo. 2023-113) SEc. 6213; petitions to Tax Court; 90-day filing deadline missed; absence from U.S.; failure to show out of country during critical times.
Andrew Bill Katakis (T.C. Memo. 2023-112) Sec. 7623; expenses of detection of underpayment and fraud; dismissed for lack of jurisdiction; failure to include specific information.
Lakepoint Land Il, LLC, Lakepoint Land Group, LLC, Tax Matters Partner (T.C. Memo. 2023-111); Sec. 6673; penalty for delay; IRS failure to timely advise Tax Court of issue with IRS statements; awarding of costs premature.
Bonnie Lem (T.C. Memo. 2023-110) Sec. 6330; hearing before levy; collection due process; CDP; failure to provide requested financial information; rejection of collection alternative; relevant issues considered.
R.J. Channelsz, Inc (T.C. Memo. 2023-109) Sec. 6662; accuracy-related penalty; reconstruction of notice of deficiency; doubt as to accuracy of penalty.
James Mellon (T.C. Memo. 2023-108) Sec. 7345; revocation or denial of passport of certain tax delinquencies; seriously delinquent tax debt; removal of certification by IRS.
Steven Jacobowitz (T.C. Memo. 2023-107) Sec. 6050P; cancellation of indebtedness by certain entities; forgiveness of debt; COD income; LLC's debt; single member LLC; failure to make election to be taxed as corporation; disregarded entity.
Daniel E. Larkin and Christine L. Larkin; Daniel E. Larkin and Christine Larkin (T.C. Memo. 2023-106) Sec. 7485; bond to stay assessment and collection; revised decisions on vacated cases; computations in dispute.
Gary J. Sinopoli, Jr. and Melissa M. Sinopoli, et al. (T.C. Memo. 2023-105) Sec. 162; 280A; business expenses; home office; rent paid for use of home by S corporation; substantiation of meetings; documentation; marketing expenses paid to related entity.
Michael G. Parker and Julie A. Parker (T.C. Memo. 2023-104) Sec. 108; cancellation of debt income; nonrecourse debt; included in property sale price; insolvency; cancellation of debt linked to property sale.
Michael J. Golden (T.C. Memo. 2023-103) Sec. 6512; Tax Court petition; refund barred by statute; two-year lookback period from payment of tax; failure to file a return; notice of deficiency issued.
Kevin Anthony Jenkins (T.C. Memo. 2023-102) Sec. 6201; 6662; assessment authority; accuracy-related penalty; overpayments properly applied to accounts; account transcripts shown to be correct.
Marisol Severance (T.C. Memo. 2023-101) Sec. 6015; innocent spouse relief; timeliness of request for relief; reason to know claim of foreign income exclusion; management of financial affairs; duty to inquire.
Thomas D. Conrad and Margaret Joan Conrad (T.C. Memo. 2023-100) Sec. 162; 167; 280A; 6662; business expenses; depreciation; home office deduction; accuracy-related penalty; depreciation on yacht and airplane owned by corporation; placed in service.
Adam Sowards (T.C. Memo. 2023-99) Sec. 24; 32; child tax credit; earned income tax credit; identification number requirement for child tax credit; spouse not eligible for Social Security number and not eligible.
Suzanne Jean McCrory (T.C. Memo. 2023-98) Sec. 7623; expenses of detection of underpayments and fraud; jurisdiction by Tax Court.
William Henry McGhee (T.C. Memo. 2023-97) Sec. 61; 6651; gross income definition; failure to file or pay; settlement for age discrimination taxable; no exception to taxability shown.
Lawrence James Saccato (T.C. Memo. 2023-96) Sec. 61; 1222; 6651; 6654; 6673; gross income definition; other definitions (capital gains); failure to file or pay; failure to pay estimated tax; penalty for delay; capital gain on sale of property; taxable Social Security benefits; cancellation of indebtedness income; frivolous arguments.
Reynold Harvey (T.C. Memo. 2023-95) Sec. 61; 72; 6651; 6673; gross income definition; distributions from pension plans; failure to file or pay; frivolous arguments; distributions from qualified retirement plans taxable.
Michael J. Stevens and Alexis M. Stevens (T.C. Memo. 2023-94) Sec. 6330; hearing before levy; collection due process; CDP; determination of income and expenses based on Form 433-A to conform to standards; rejection of installment agreements by taxpayers.
Arlin G. Hatfield, III and Jennifer W. Hatfield (T.C. Memo. 2023-93) Sec. 61; 6662; 6673; gross income definition; accuracy-related penalty; penalty for delay; frivolous argument; failure to report wages.
Dorchester Farms Property, LLC, Dorchester Farms Manager, LLC, Tax Matters Partner (T.C. Memo. 2023-92) Sec. 6751; procedural requirements; supervisory approval of penalty; digitally approved; challenge of approval based on time spent by supervisor.
James H. Kim (T.C. Memo. 2023-91) Sec. 1212; 1222; capital loss carrybacks and carryovers; definitions relating to capital gains and losses; virtual currency transactions; crypto currency; estoppel; actions by the government.
Laidlaws Harley Davidson Sales, Inc. T.C. Memo. 2023-90) Sec. 6320; 6330; 6751; hearing on filing lien notice; hearing before levy; procedural requirements; collection due process; CDP; supervisory approval of penalty; settlement officer precluded from verifying penalty; set aside of prior decision.
Richard John Cardulla (T.C. Memo. 2023-89) Sec. 162; 163; 469; 6662; business expenses; interest; passive activity losses; accuracy-related penalty; deductions related to rental real estate; depreciable basis; bona fide loan; accrual of unpaid interest on note.
Greg A. Ninke and Jane M. Ninke (T.C. Memo. 2023-88) Sec. 61; 6662; 6751; gross income definition; accuracy-related penalty; procedural requirements; unreported income; reconstruction of income; bank deposits method; justification of analysis; transfers between accounts; redepositing of cash; supervisory approval of penalty.
Cassandra Tucker and Edward Brodie (T.C. Memo. 2023-87) Sec. 162; 163; 280A; business expenses; interest expense; business use of home; substantiation.
William G. Allen v. Commissioner; Humbolt Investments, LLC, Allen Family Investment Trust U/a/d 12/1/03, Tax Matters Partner (T.C. Memo. 2023-86) Sec. 166; 6662; bad debts; accuracy-related penalty; loans to affiliated companies; bona fide debt; factors weighed; capital infusion; loan terms; equity vs. debt.
Janet R. Braen, et al. (T.C. Memo. 2023-85) Sec. 170; 6651; 6662; charitable contributions; failure to file or pay; accuracy-related penalty; sale to municipality; bargain sale; pass-through by S corporation; substantial valuation misstatement.
Mark Betz and Christine Betz; Dennis Lincoln and Julia Lincoln (T.C. Memo. 2023-84) Sec. 41; 174; 6662; research tax credit; research and experimental expenses; proof expenditures for pilot models; qualified research activities; retention of rights in research; expenditures funded by others.
American Milling, LP, UN Limited, Tax Matters Partner (T.C. Memo. 2023-83) Sec. 6221; determination at partnership level; statutory period for assessing tax attributable to partnership items not open.
Glade Creek Partners, LLC, Sequatchie Holdings, LLC, Tax Matters Partner (T.C. Memo. 2023-82) Sec. 170; charitable contributions; conservation easement; ordinary income property; deduction limited to taxpayer's adjusted basis in property; property formerly inventory; proof not inventory property.
Donald E. Swanson (T.C. Memo. 2023-81) Sec. 183; 6651; not-for-profit activities; failure to file or pay; hobby losses; charter fishing activity; profit intent; failure to maintain books and records; bank deposits method; income reconstructed; factors weighed.
Neel Kamal and Preeti Sharma (T.C. Memo. 2023-80) Sec. 162; 6663; business expenses; civil fraud; taxation of incentive stock options; basis; business expenses not related to any trade or business; substantiation of business expenses; documentation; recordkeeping.
Joshua Elias Raffaelli (T.C. Memo. 2023-79) Sec. 7623; expenses of detection of underpayment and fraud; whistleblower award; claim dismissal resulting from no action taken based on claimant's information; no credible information.
Henry Seggerman (T.C. Memo. 2023-78) Sec. 6330; hearing before levy; collection due process; CDP; restitution based assessment; RBA; notice of federal tax lien; NFTL affecting ability to pay.
Katrina E. White (T.C. Memo. 2023-77) Sec. 108, cancellation of indebtedness; COD; cacellation of debt income; insolvency exception; breach of lease agreement created liability.
Patricial Hyde (T.C. Memo. 2023-76) Sec. 6320; 6330; hearing on filing notice of lien; hearing before levy; collection due process; CDP; jurisdiction by Tax Court; valid notice of discretion; frivolous arguments; failure to propose collection alternatives.
Noel M. Parducci and Kenneth L. Parducci, et al. (T.C. Memo. 2023-75) Sec. 6061; signing of individual tax returns; failure to sign return; not a valid return; authorized agent to sign return.
Anthony J.A. Bryan, Jr. (T.C. Memo. 2023-74) Sec. 465; 704; 6651; at-risk rules; partner's distributive share; failure to file or pay; outside basis in partnership; pass-through of losses; partnership operating agreement; personal liability; net operating losses.
Murfam Enterprises LLC, Wendell Murphy, JR., Tax Matters Partner (T.C. Memo. 2023-73) Sec. 170; 6662; charitable contributions; accuracy-related penalty; conservation easement; failure to comply with substantiation and reporting requirements; substantial compliance; failure to report cost basis; reasonable cause; gross valuation and misstatement penalty.
Wendell H. Murphy, Jr. and Wendy F. Murphy; Wendell H. Murphy and Linda G. Murphy (T.C. Memo. 2023-72) Sec. 170; 6662; charitable contributions; accuracy-related penalty; conservation easement; failure to comply with substantiation and reporting requirements; substantial compliance; failure to report cost basis; reasonable cause; gross valuation and misstatement penalty.
Claude Franklin Sanders (T.C. Memo. 2023-71) Sec. 1; 6651; 6654; imposition of tax; failure to file or pay; failure to pay estimated tax; frivolous argument; definition of individual.
Haruki Yamada; Yasuko Ogawa (T.C. Memo. 2023-70) Sec. 7430; recovery of litigation costs; substantially prevailed; IRS substantially justified.
Tyrone Dietz and Toni Dietz (T.C. Memo. 2023-69) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; CDP; failure to provide documentation with respect to issue; failure to provide financial information; entitlement to collection alternatives; determination of reasonable collection potential; failure to respond to IRS correspondence.
Salacoa Stone Quarry, LLC, Eco Terra 2017 Fund, LLC, Tax Matters Partner (T.C. Memo. 2023-68) Sec. 6751; procedural requirements; supervisory approval of penalty; timing of approval.
Joseph William Kovach (T.C. Memo. 2023-67) Sec. 6212; 6330; notice of deficiency; hearing before levy; collection due process; CDP; challenge of underlying liabillity; petition to Tax Court; no collection alternatives proposed.
Frank Warren Bibeau (T.C. Memo. 2023-66) Sec. 1402; self-employment tax definitions; Chippewa tribe and U.S. government; treaties; ability to tax tribe; exemption from taxation.
Ronald Schlapfer (T.C. Memo. 2023-65) Sec. 6501; limitations on assessment and collection; gift tax; adequate disclosure on prior year's return; disclosure started commencement of limitations period.
Cardiovascular Center, LLC (T.C. Memo. 2023-64) Sec. 3402; 6302; 6651; income tax collected at source; mode or time of collection; failure to file or pay; employee vs. independent contractor; classified employees; seven factors considere; reasonable basis for worker classification.
Joseph William Sherman (T.C. Memo. 2023-63) Sec. 162; 183; 6651; business expenses; not for profit activities; failure to file or pay; hobby losses; nine factors weighed; ordinary and necessary expenses; reasonable cause for failure to file.
Memorial Hermann Accountable Care Organization (T.C. Memo. 2023-62) Sec. 501; tax-exempt organization; Medicare Shared Savings Program; MSSP; Accountable Care Organization; ACO; not operated exclusively for the promotion of social welfare.
Guy Alvarez Gayou (T.C. Memo. 2023-61) Sec. 7345; revocation or denial of passport; seriously deliquent tax debt; proof of legally enforceable tax liabilities; lien notice attached; no valid exceptions noted.
Benjamin Soleimani and Sharyn Soleimani (T.C. Memo. 2023-60) Sec. 165; 6662; losses; accuracy-related penalty; long-term capital loss; property seized by Iranian government; documents presented were found to be forgeries; deficiencies in penalty form did not fatal; intention to assert penalty; accurate information not provided tax adviser.
Duane Whittaker and Candace Whittaker (T.C. Memo. 2023-59) Sec. 6330; hearing before levy; collection due process; CDP; material change in taxpayers' circumstances; abuse by settlement officer; remand to IRS Appeals Office.
Aubree Hill (T.C. Memo. 2023-58) Sec. 6330; hearing before levy; collection due process; CDP; offer-in-compromise never submitted by taxpayer.
Jeffrey A. Harper and Katherine M. Harper (T.C. Memo. 2023-57) Sec. 41; credit for increasing research activities; definition of business components; one of four tests; qualified research.
Susan D. Rodgers (T.C. Memo. 2023-56) Sec. 61; gross income definition; taxable interest income vs. nontaxable child support; interest on late child support; wording of order by Alabama court.
ES NPA Holding, LLC, Joseph NPA Investment, LLC, Tax Matters Partner (T.C. Memo. 2023-55) Sec. 721; 6662; nonrecognition of gain or loss on contribution; accuracy-related penalty; LLC; profits interest; income excludable; Rev. Proc. 93-27; provision of services to LLC.
Estate of Anthony R. Tanner, Deceased, Marglen M. Tanner, Personal Representative (T.C. Memo. 2023-54) Sec. 932; 6501; coordination of U.S. and Virgin Islands income taxes; limitations on assessment and collection; bona fide resident of U.S. Virgin Islands; application of Reg. Sec. 1.932-1(c)(2)(ii); effective date of regulation; filing of U.S. Virgin Islands return does not begin running of statute of limitations.
Nick A. Kolev (T.C. Memo. 2023-53) Sec. 6211; deficiency defined; diversion of tax refund for child support; credit claimed on return.
Ludwig Prufer Vollers III (T.C. Memo. 2023-52) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; abuse of collection actions; requirements met by settlement officer; failure to propose collection alternatives.
Suzanne Jean McCrory (T.C. Memo. 2023-51) Sec. 7623; expenses of detection of underpayment and fraud; whistleblower awards; failure of IRS to proceed with any action; claims not specific, credible, or were speculative; Tax Court jurisdiction.
North Donald LA Property, LLC, North Donald LA Investors, LLC, Tax Matters Partner (T.C. Memo. 2023-50) Sec. 170; 6751; charitable contribution; procedural requirements; conservation easement; easement protected in perpetuity; right to mine subsurface minerals retained; dispute of facts; supervisory approval of penalty.
George Luniw (T.C. Memo. 2023-49) Sec. 6330; 6671; hearing before levy; penalty for delay; collection due process; challenge of underlying tax liabilities; receipt of notice of deficiency; failure to petition Tax Court; frivolous arguments; warning by Tax Court.
Ronald Powell and Cynthia Powell (T.C. Memo. 2023-48) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; claim of mailing financial information not shown; failure to negotiate collection alternatives; streamlined installment agreement.
Edwin L. Gage and Elaine R. Gage (T.C. Memo. 2023-47) Sec. 162; 6662; business expenses; accuracy-related penalty; settlement payment to Department of Housing and Urban Development; date of receipt of check; end of year check; penalty or compensatory payment; deductibility. Tyrone Burnett (T.C. Memo. 2023-46) Sec. 61; 6651; 6654; 7491; gross income definition; failure to file or pay; failure to pay estimated tax; burden of proof; valid notice of deficiency; signature of IRS employee; failure to report retirement income.
Whistleblower 9252-18W (T.C. Memo. 2023-45) Sec. 7623; expenses of detection of underpayment and fraud; information supplied before enactment of Code Section; lack of jurisdiction.
Robert A. Di Giorgio, Sr.; Robert A. Di Giorgio, Sr. and Zandra M. Di Giorgio (T.C. Memo. 2023-44) Sec. 61; 6015; 6651; 6663; gross income definition; innocent spouse relief; failure to file or pay; fraud penalty; underreporting of income; spouse entitled to relief from penalty; bank deposits analysis; badges of fraud.
Thomas K. Richey and Maureen P. Cleary (T.C. Memo. 2023-43) Sec. 165; losses; casualty losses; substantiation of cause of loss; documentation of amount of loss.
William French Anderson and Kathryn D. Anderson (T.C. Memo. 2023-42) Sec. 162; business expenses; deduction of legal expenses on personal tax return; investigation expenses of former colleague; proof of relation to taxpayer's business; damage to business collateral consequence.
Duncan Bass (T.C. Memo. 2023-41) Sec. 162; 170; 274; 6662; business expenses; charitable contributions; business expense substantiation; accuracy-related penalty; vehicle expenses; contemporaneous log; failure to get appraisal on household items totaling more than $5,000; noncash charitable gifts; accuracy-penalty partially sustained and partially not sustained.
Conmac Investments Inc. (T.C. Memo. 2023-40) Sec. 446; 481; methods of accounting; adjustments for changes in accounting methods; rented out acreage base; from nonamortizable to amortizable; failure to identify facts that changed; present value of future farm program subsidy payments; adjustments include amounts for time-barred years.
Greatest Common Factor (T.C. Memo. 2023-39) Sec. 162; 167; 274; 280A; 6662; business expenses; depreciation; business expense substantiation; home office deductin; accuracy-related penalty; claim of home office deduction by corporastion; no rental agreement; documentation; substantiation; vehicle expenses; mileage log; business purpose; commuting expenses; supporting documentation for depreciation..
Darcy-Mae Englert (T.C. Memo. 2023-38) Sec. 61; 6673; gross income defined; penalty for delay; frivolous arguments; payments received for work performed; taxable income; penalty assessed; warning by Court.
Charles Lin and Amy Lin (T.C. Memo. 2023-37) Sec. 86; 469; social security benefits; passive activity losses; calculation of modified adjusted gross income; rental of room to close friend; modest rent; profit seeking activity; portion of additional expenses attributable to rental activity; documentation.
Nassau River Stone, LLC GH Manager, LLC, Tax Matters Partner (T.C. Memo. 2023-36) Sec. 6751; procedural requirements; supervisory approval of penalty; proper individuals to approve penalty; immediate supervisor.
Arland T. Keeton a.k.a. Arland Keeton and Ima Jean Keeton (T.C. Memo. 2023-35) Sec. 166; 6662; bad debts; accuracy-related penalty; bad debt deduction; bona fide debt; repayment requirement; debt vs. capital contribution; pass-through loss; net operating loss; NOL.
Estate of Scott M. Hoensheid, Deceased, Anne M. Hoensheid, Personal Representative, and Anne M. Hoensheid (T.C. Memo. 2023-34) Sec. 170; 6662; charitable contributions; accuracy-related penalty; no qualified appraisal; appraisal missing required information.
Estate of Bernard J. Macelhenny, Jr., Deceased, Donor, Michael P. Macelhenny and Catherine Macelhenny Dann, Co-executors v. Commissioner; Estate of Bernard J. Macelhenny, Jr., Deceased, Michael P. Macelhenny and Catherine Macelhenny Dann, Co-executors (T.C. Memo. 2023-33) Sec. 2053; 2512; deductions against gross estate; valuation of gifts; property purchased at a discount; deduction for consent judgments; arm's-length bargain; obligation for debts.
Russell E. Barrios (T.C. Memo. 2023-32) Sec. 162; 6651; 6654; business exppenses; failure to file or pay; failure to pay estimated taxes; substantiation; documentation; recordkeeping; reconstruction of records; business purpose of expenditures; failure to raise issues.
George B. Dengin (T.C. Memo. 2023-31) Sec. 402; 794; 6038D; 6048; 6677; beneficiary of employees' trust; employees' trusts; information with respect to foreign financial assets; information with respect to certain foreign trusts; failure to file information with respect to certain financial trusts; Candian registered retirement savings plan.
Estate of Susan R. Block, Deceased, Julie B. Saffir and Peter A. Block, Executors (T.C. Memo. 2023-30) Sec. 664; 2055; charitable remainder trusts; transfers for public, charitable andreligious uses; CRAT; requirement of payment of sum certain to income beneficiaries; qualified reformation; more than 90 days after estate tax return due.
Techtron Holding, Inc. (T.C. Memo. 2023-29) Sec. 6212; 6903; notice of deficiency; notice of fiduciary relationship; merger; taxpayer ceased to exist; capacity to petition Tax Court; valid notice of deficiency; petition not filed on behalf of proper party.
Mehlek Dawveed T.C. Memo. 2023-28) Sec. 6201; 6320; 6330; assessment authority; hearing before filing lien notice; hearing beforr levy; collection due process; challenge of restitution based assessment; eligibility for collection alternative; failure to submit financial information; prior criminal case.
Commonwealth Underwriting & Annuity Services, Inc. (T.C. Memo. 2023-27) Sec. 501; exemption from tax on corporations; sale of annuitie by company; gross receipts threshold.
Joseph Amundsen (T.C. Memo. 2023-26) Sec. 162; 274; 280A; 6662; business expenses; business expense substantiation; home office expenses; accuracy-related penalty; Cohan rule; documentation; recordkeeping; travel and entertainment expenses; T&E; per diem expenses; away from home; evidence of work performed at home; use for clients; principal place of business; relationship of expenses to business.
Estate of Richard D. Spizzirri, Deceased, John J. McAtee, Jr., Personal Representative (T.C. Memo. 2023-25) Sec. 2053; 2501; 6651; deductions against gross estate; gift taxes; failure to file or pay; deduction for payments to stepchildren; gifts vs. payments for care; checks not identified as compensation; no Forms 1099 or W-2 issued.
Estate of William A.V. Cecil, Sr., Donor, Deceased, William A.V. Cecil, Jr.; Estate of Mary R. Cecil, Donor, Deceased, William A.V. Cecil, Jr., Co-executor (T.C. Memo. 2023-24) Sec. 2512; valuation of gifts; transfer of closely held stock; split gifts; tswo of three appraisals rejected; discount for lack of control; discount for lack of voting rights; discount for marketability.
Kevin B. CXheam and Julie Lim (T.C. Memo. 2023-23) Sec. 61; 6662; gross income definition; accuracy-related penalty; unreported income; failure to maintain books and records; substantiation of income and expenses; documentation; nontaxable sources of income.
Lundy Nath and Tanya Nath (T.C. Memo. 2023-22) Sec. 61; 6662; gross income definition; accuracy-related enalty; unreported income; advances were income; income vs. loan; intention to repay.
Estate of Pearl B. Kalikow, Deceased, Eugene Shalik, Executor, and Edward M. Kalikow and Laurie K. Platt, Limited Administrators (T.C. Memo. 2023-21) Sec. 2044; 2054; property for which marital deduction previously allowed; deductions against gross estate; qualified terminable interest property; QTIP trust; date of death value included in gross estate; valuation of family limited partnership; deduction for settlement payment.
Scott Moore and Gayla Moore (T.C. Memo. 2023-20) Sec. 41; credit for increasing research expenditures; S corporation; proper accounting for employee's wages; documentation; recordkeeping; time spent on qualified research.
Leigh C. Fairbank and Barbara J. Fairbank (T.C. Memo. 2023-19)Sec. 6048; 6501; 6662; information with respect to foreign trusts; limitations on assessment and collection; accuracy-related penalty; notice of deficiency not time barred; failure to file information returns on foreign accounts.
James William Avery (T.C. Memo. 2023-18) Sec. 162; 6651; business expenses; failure to file or pay; substantiation of expenses; racing car activity and relationship to business; advertising epenses; hobby loss; ordinary and necessary expenses of business.
Cattail Holdings, LLC, Cattail Holdings Investments, LLC, Tax Matters Partner (T.C. Memo. 2023-17) Sec. 170; 6751; charitable contributioins; procedural requirements; conservation purpose protected in perpetuity; right to exploit mineral interest; supervisory approval of penalty.
Tony Patrinicola and Barbara Partinicola (T.C. Memo. 2023-16) Sec. 61; gross income definition; pension distributions taxable.
Tanisha Trice (T.C. Memo. 2023-15) Sec. 25A; 6201; lifetime learning credit; assessment authority; phaseout of benefit; AGI; portion of social security benefits taxable.
Indu Rawat (T.C. Memo. 2023-14) Sec. 741; 751; 865l recognition and character of gain or loss on sale or exchange; unrealized receivables and inventory; source rules for personal property sales; sale of partnership interest; inventory property.
Willard J. Belton and Martha-Alexander Belton (T.C. Memo. 2023-13) Sec. 6331; 7345; levy and distraint; revocation or denial of passport; jurisdiction to redetermine tax liability related to Sec. 7345; requirements of Sec. 7345 outlined; proper levy.
Hrach Shilgevorkyan (T.C. Memo. 2023-12) Sec. 164; interest; mortgage interest; qualified residence; substantiation; legal or equitable owner of property; debt must be taxpayer's obligation.
Calvin A. Lim and Helen K. Chu (T.C. Memo. 2023-11) Sec. 170; charitable contributions; contribution of LLC units; failure to satisfy requirements; proof of transfer of LLC units; attorney fee prohibited transaction; fee based on value of units; qualified appraiser; requirements of qualified appraiser.
Kari Jane Freman and Rodney C. Freeman (T.C. Memo. 2023-10) Sec. 6015; innocent spouse relief; lack of knowledge; lack of actual knowledge; knowledge or reason to know; factors weighed.
Rober B. Lucas (T.C. Memo. 2023-9) Sec. 72; qualified plan distributions; premature distribution; exception to early withdrawal penalty; qualified disability.
Ernesto P. Patacsil and Marilyn E. Patacsil (T.C. Memo. 2023-8) Sec. 108; 162; 172; 6664; cancellation of indebtedness income; business expenses; net operating loss; reasonable cause; NOL; proof insolvent; properties foreclosed on; depreciation taken; recordkeeping; reliance on professional.
Joseph Decrescenzo (T.C. Memo. 2023-7) Sec. 6211; 6212; 6651; 6662; 6673; deficiency defined; notice of deficiency; failure to file or pay; accuracy-related penalty; penalty for delay; substitute for return; SFR; no defense for additions to tax.
Cory H. Smith (T.C. Memo. 2023-6) Sec. 119; Meals or lodging furnished for convenience of employer; relationship of housing provided to work; integral to employer's business.
Paul C. Wondries and Patricia Wondries (T.C. Memo. 2023-5) Sec. 183; not-for-profit activities; hobby losses; ranching activity; professional counsel; recordkeeping; change in focus to improve profitability; appreciation of property.
Kyle D. Simpson and Christen Simpson (T.C. Memo. 2023-4) Sec. 67; 162; 274; 6651; 6662; miscellaneous itemized deductions; business expenses; business expense substantiation; failure to file or pay; accuracy-related penalty; unreimbursed business expenses; documentation; recordkeeping; basis in LLC not substantiated; accountable plan for employee expenses.
XC Foundation (T.C. Memo. 2023-3) Sec. 7428; declaratory judgments for charitable organizations; revocation of exempt status; corporate powers revoked by secretary of state; lack of jurisdiction.
Marie L. Henry (T.C. Memo. 2023-2) Sec. 36B; premium tax credit; required repayment of credit; qualified coverage terminated for nonpayment; documentation to support termination; household income in excess of 400 percent of federal proverty line.
Ryan Charles Minnig (T.C. Memo. 2023-1) Sec. 61; 6662; 6673; gross income definition; accuracy-related penalty; frivolous arguments; unreported wage income; warning of frivolous argument penalty.

Summary Opinions

Sean Paul Polete (T.C. Summary Opinion 2023-35) Sec. 6020; 6651; 6654; substitute for return; failure to file or pay; failure to pay estimated tax; expense deduction related to businesses, real estateproperties.
Kristen L. Quevy (T.C. Summary Opinion 2023-34) Sec. 61; 104; gtpss income definition; damage awards and sick pay; severance pay; emotional distress; nature of the claim; terms of court agsreement.
Sean Patrick Canavan (T.C. Summary Opinion 2023-33) Sec. 85 social security benefits; taxability; disabled; payments not designated as SSI.
Georgianna Shepard (T.C. Summary Opinion 2023-32) Sec. 6330; hearing before levy; collection due process; CDP; failure of taxpayer to avail herself of opportunity to challenge ability to pay.
Andrew L. Harrell and Katherine L. Harrell (T.C. Summary Opinion 2023-31) Sec. 162; 274; 6662; business expenses; business expense substantiation; accuracy-related penalty; unreimbursed employee business expenses; recordkeepiang; documentation; policy of employer.
Joseph Amundsen and Anna Amundsen (T.C. Summary Opinion 2023-30) Sec. 162; 6662; business expenses; accuracy-related penalty; cost of goods sold; lack of specific expense detail; personal expenses.
Raymond S. Edwards (T.C. Summary Opinions 2023-29) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; CDP; failure to timely file returns and pay employment taxes.
Jie Ranieri a.k.a. Jie Hu and Paul Ranieri (T.C. Summary Opion 2023-28) Sec. 6662; accuracy-related penalty; net operating losses; failure to elect out of NOL carryback; failure to carry back loss.
Mark P. Hafner (T.C. Summary Opinion 2023-27) Sec. 6330; hearing before levy; collection due process; CDP; trust fund recovery penalty; TFRP; failure to pay.
Nuntiya Sripa (T.C. Summary Opinion 2023-26) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; CDP; offer in compromise; doubt as to liability.
Robert R. Doggart (T.C. Summary Opinion 2023-25) Sec. 6651; 6654; failure to file or pay; failure to pay estimated tax; incarceration; constructive distribution from life insurance; rental of property at less than fair market rent.
Karim Gobran and Ashley Smith-Gobran (T.C. Summary Opinion 2023-24) Sec. 162; 262; 274; 6651; 6662; business expenses; personal expenses; business expense substantiation; failure to file or pay; accuracy-related penalty; withholding of employment taxes; recordkeeping; documentation.
Fernando Ponce and Natalie Ponce (T.C. Summary Opinion 2023-23) Sec. 61; gross income definition; unreported income; lead plaintiff in class action suit; service award; claim of expenses incurred.
Frank R. McNamara and Collette M. McNamara (T.C. Summary Opinion 2023-22) Sec. 163; interest expense; mortgage deduction; qualified residence interest; maximum principal outstanding; average principal outstanding; Publication 936; time mortgage securted by taxpayer's home.
Ariana K. Uchizono (T.C. Summary Opinion 2023-21) Sec. 6662; accuracy-related penalty; miscellaneous itemized deductions; education expenses; work towards MBA.
Donald S. Tracy (T.C. Summary Opinion 2023-20) Sec. 6651; failure to file or pay; reasonable cause; employment taxes; extenuating circumstances.
Joseph Michael Ledbetter and Ashley Jones Ledbetter (T.C. Summary Opinion 2023-19) Sec. 67; 274; 2% floor; business expense substantiation; unreimbursed business expenses; commuting; away from home; vehicle expenses; recordkeeping; documentation.
Anthony Vennard Hitchman (T.Cr. Summary Opinion 2023-18) Sec. 454; 691; discount obligations; income in respect of a decedent; U.S. savings bonds; issued at a discount; discount reportable ratably or at maturity; savings bond inherited.
Cynthia L. Hailstone and John Linford (T.C. Summary Opinion 2023-17) Sec. 105; 6015; 6662; amounts received from accident and health plans; innocent spouse relief; accuracy-related penalty; disability insurance provided by company; amount received taxable.
Gregory F. Teague and Rachel S. Teague (T.C. Summary Opinion 2023-16) Sec. 468; passive activity losses; real estate professional; records of time spent; grouping of activities; requisite time spent.
John J. Evan and Carissa R. Clark (T.C. Summary Opinion 2023-15) Sec. 53; 55; credit for prior year minimum tax; minimum tax; imposition of minimum tax in prior years not shown.>br> Noah Schmerling and Susana Schmerling (T.C. Summpary Opinion 2023-14) Sec. 162; 274; 280A; 6662; business expenses; business expense substantiation; home office; accuracy-related penalty; vehicle expenses; travel and entertainment; unreimbursed employee business expenses vs. Schedule C sole proprietorship; mileage log.
Magdy A. Ghaly and Laila Ryad (T.C. Summary Opinion 2023-13) Sec. 61; 72; 402; 6662; gross income definition; distributions from annuities; taxability of beneficiary of employees' trust; accuracy-related penalty; default on loan from retirement account; exceptions to penalty.
Robert L. Drocella and Pamela M. Drocella (T.C. Summary Opinion 2023-12) Sec. 162; 212; 469; business expenses; expenses for the production of income; passive activity losses; multiple rentsal properties; time spent working on properties; hours performed in regular employment; threshold requirements for real estate professional.
Chalaundra Edjewel Sneed (T.C. Summary Opinion 2023-11) Sec. 36B; 6662; premium tax credit; accuracy-related penalty; adjusted gross income for premium tax credit.
Jonathan Cole Philips and Eva V. Phillips (T.C. Summary Opinion 2023-10) Sec. 62; 162; 179; 274; miscellaneous itemized deductions; business expenses; expensing business assets; business expense substantiation; vehicle expenses; employee business expenses; meal and entertainment exp0enses.
Thomas Laronn Mitchell (T.C. Summary Opinion 2023-9) Sec. 162; 274; business expenses; business expense substantiation; vehicle expenses; travel expenses; inconsistencies in log.
Alberto Delgado and Virginia Delgado (T.C. Memo. 2023-8) Sec. 61; unreported income; validity of deficiency notice.
Donald S. Ahaiwe (T.C. Summary Opinion 2023-7) Sec. 61; 108; gross income definition; cancellation of debt income; COI; credit card debt forgiven; Form 1099-C; claim of fraudulent charges; claim of insolvency; documentation; substantiation.
Ahmed Maregn Mohamed (T.C. Summary Opinion 2023-6) Sec. 6015; innocent spouse relief; threshold conditions; knowledge of items giving rise to unreported income; review of factors considered.
Francis Kemegue (T.C. Summary Opinion 2023-5) Sec. 6651; failure to file or pay; reasonable cause; engaged in other activities.
Mathew Daniel Craddock and Chasta Crenshaw Craddock (T.C. Summary Opinion 2023-4) Sec. 162; 274; business expenses; business expense substantiation; auto and truck expenses; documentation; recordkeeping; car log or diary.
Terrence Edward Aragoni (T.C. Summary Opinion 2023-3) Sec. 71; 6662; alimony; accuracy-related penalty; payments to spouse's attorney; payments to survive death of spouse; state law.
Ashenafi Getachew Mulu (T.C. Summary Opinion 2023-2) Sec. 6662; accuracy-related penalty; reasonable cause; failure to review return; reliance on tax preparer.
John M. Vassiliades and Eliza Ortizluis Vassiliades (T.C. Summary Opinion 2023-1) Sec. 25A; American Opportunity Tax Credit; failure to produce tuition receipts.

--Last Update 12/23/23