Small Business Taxes & Management

Tax Court Cases--2021


Small Business Taxes & ManagementTM--Copyright 2021, A/N Group, Inc.

 

Below is a list of the 2021 cases of the U.S. Tax Court with direct links to the full text at the Tax Court web site. The text of the cases is in PDF format, so an Adobe Acrobat Reader is required. The list below contains the case name, cite, the Code sections and key words for the issues in the case. 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. Keep in mind that you can go to the U.S. Tax Court at www.ustaxcourt.gov and use their search engine (use the "Opinions Search" tab) to look for additional cases or words that we have not indexed. Their site contains full Tax Court cases (TC) and Tax Court Memorandum Opinions starting September 25, 1995 and Summary Opinions starting January 1, 2001.

NOTE--The U.S. Tax Court is significantly revising its system of presenting cases and other information. Once the system is fully operational you will be able to retrieve cases back to May 1986. However, at this time none of the links on any of our pages will take you to the indicated cases. We regret the inconvience and will advise as soon as the government's system is fully operational.

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

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

 

New Additions - Week Ended December 4, 2021

Tax Court Cases

None

 

Memorandum Decisions

Om P. Soni and Anjali Soni (T.C. Memo. 2021-137) Sec. 6013; 6501; 6651; 6662; joint returns; limitations on collection and assessment; failure to file or pay; accuracy-related penalty; valid joint return; agreement to file joint; Forms 872; consent to extend limitations period.
Hong Jun Chan and Suzhen Mei (T.C. Memo. 2021-136) Sec. 1362; 6651; 6654; 6662; S corporation election; failure to file or pay; failure to pay estimated tax; accuracy-related penalty; reconstruction of income; valid S corporation election.

 

Summary Opinions

Nowran Gopi (T.C. Summary Opinion 2021-41) Sec. 1; 24; 32; 151; individuial income tax; child tax credit; earned income tax credit; personal exemption; head of household status; dependency exemption; granddaughter; father claimed exemption for same child; qualifying child.
Donald G. Swyers (T.C. Summary Opinion 2021-40) Sec. 162; 170; 274; 6662; business expenses; charitable contributions; business expense substantiation; accuracy-related penalty; unreimbursed employee business expenses; substantiation of vehicle expenses; recordkeeping; documentation; Schedule C expenses; employee vs. independent contractor.

 

Cumulative Cases - 2021

Tax Court Cases

Sand Investment Co., LLC, Inland Capital Management, LLC, Tax Matters Partner (157 T.C. No. 11) Sec. 6751; procedural requirements; supervisory approval of penalty; promotion of revenue agent to supervisor; former team manager; definiton of immediate supervisor.
Andrew Mcnulty and Donna Mcnulty (157 T.C. No. 10) Sec. 408; 6664; individual retirement accounts; reasonable cause; constructive or actual receipt of IRA assets; taxable distribution; professional advice not sought.
William E. Ruhaak (157 T.C. No. 9) Sec. 6330; 6673; hearing before levy; penalty for delay; collection due process; equivalent hearing; principal position not frivolous; incorrect reading of authority.
Joseph A. Insinga (157 T.C. No. 8) Sec. 7623; expenses of detection of underpayments and fraud; whistleblower; substitution of taxpayer's estate for taxpayer; Tax Court had jurisdiction despite death of taxpayer.
Charles H. Leyh (157 T.C. No. 7) Sec. 62, 71, 215, 265, adjusted gross income definition; alimony; alimony; expenses relating to tax-exempt income; health insurance purchased through a cafeteria plan provided to ex-spouse; deduction as alimony.
Nilda E. Vera (157 T.C. No. 6) Sec. 6015; innocent spouse relief; jurisdiction; unambiguous denial of relief; untimely petition.
Michael Lissack (157 T.C. No. 5) Sec. 7623; expenses of detection of underpayment and fraud; whistleblower claim; no proceeds collected as a result of whistleblower's information.
Catherine S. Toulouse (157 T.C. No. 4) Sec. 1411; 6651; net investment income tax; failure to file or pay; foreign tax credit not usable against net investment income tax; U.S.-France, U.S.-Italy tax treaties; citizen residing in foreign country; unresolved issues with respect to failure to pay tax due on return.
Bobby Lee Rogers (157 T.C. No. 3) Sec. 7623; expenses of detection of underpayment and fraud; nine whistleblower claims submitted; rejection of claim for failure to meet requirements; rejection vs. denial; consistency with regulations; IRS's failure to address monetary threshold factor in response at trial; review of determination by Court.
Mary T. Belair (157 T.C. No. 2) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection process; eligibility for installment agreement; failure to provide financial information and delinquent tax returns in timely fashion; Form 433-A.
Morris F. Garcia, Deceased and Sharon Garcia (157 T.C. No. 1) Sec. 7345; revocation or denial of passport; separate notices to spouses of certification under Sec. 7345; taxpayers allowed to file a joint petition.

Richard S. Hussey (156 T.C. No. 12) Sec. 108; cancellation of debt income; qualified real property; business debt; reduction on property basis.
Robert Stein and Elaine Stein (156 T.C. No. 11) Sec. 7430; recovery of litigation costs; move to voluntarily dismiss.
Mylan, Inc. & Subsidiaries (156 T.C. No. 10) Sec 162; 197; 263; business expenses; amoritization of intangibles; capital expenditures; legal expenses; patent infringement litigation; legal expenses related to FDA approval of generic drug.
Ruben De Los Santos and Martha De Los Santos (156 T.C. No. 9) Sec. 301; 1372; distributions of property; S corporation fringe benefit rules; split-dollr life insurance; fringe benefit as compensation to employee; shareholder/employee; guaranteed payments not a corporate distribution.
Robert Rowen (156 T.C. No. 8) Sec. 7345; revocation of passport in certain tax deficiencies; seriously delinquent tax debt.
Mainstay Business Solutions (156 T.C. No. 7) Sec. 6404; abatements; abatement of interest; claim for refund; withdrawal of petition; discretion of IRS.
Suzanne J. McCrory (156 T.C. No. 6) Sec. 7623; expenses of detection of underpayments and fraud; whistleblower awards; recommendation of preliminary award; determination.
Brian D. Beland and Denae A. Beland (156 T.C. No. 5) Sec. 6751; procedural requirements; supervisory approval of penalty; first communication; Form 4549; partial summary judgment.
San Jose Wellness (156 T.C. No. 4) Sec. 167; 170; 260E; 6662; depreciation; charitable contributions; illegal sale of drugs; accuracy-related penalty; medical marijuana business; deductions not allowed; more than one business activity; expenses subject to Sec. 280E.
Kirgizia I. Grajales (156 T.C. No. 3) Sec. 72; 6751; qualified plan distributions; procedural requirements; supervisory approval of penalty; early distribution penalty; additional tax not penalty.
Adams Challenge (UK) Limited (156 T.C. No. 2) Sec. 882; tax on income of foreign corporations connected to U.S. business; deductions and credits denied; returns not filed by terminal date; cutoff date.
Wiley Ramey (156 T.C. No. 1) Sec. 6330; hearing before levy; collection due process; start of running of 30-day period; mail sent to last known address.

 

Memorandum Decisions

Om P. Soni and Anjali Soni (T.C. Memo. 2021-137) Sec. 6013; 6501; 6651; 6662; joint returns; limitations on collection and assessment; failure to file or pay; accuracy-related penalty; valid joint return; agreement to file joint; Forms 872; consent to extend limitations period.
Hong Jun Chan and Suzhen Mei (T.C. Memo. 2021-136) Sec. 1362; 6651; 6654; 6662; S corporation election; failure to file or pay; failure to pay estimated tax; accuracy-related penalty; reconstruction of income; valid S corporation election.
FAB Holdings LLC v. Commissioner, Frank Berritto and Estate of Dana Berritto, Deceased, Frank Berritto, Executor (T.C. Memo. 2021-135) Sec. 61; 301; 6501; gross income definition; property distributions; limitations on assessment; constructive dividends; IRS met burden of proof of reasonable connection; management fees paid to partnership.
James R. O'Donnell (T.C. Memo. 2021-134) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; CDP; failure to file returns; substitute for return; offer in compromise; failure to make estimated payments; reasonable collection potential; RCP.
Plateau Holdings, LLC, Waterfall Development Manager, LLC, Tax Matters Partner (T.C. Memo. 2021-133) Sec. 6662; accuracy-related penalty; disallowance of conservation easement; judicial extinguishment clauses; in perpetuity; overvaluation penalty; reasonable cause; good faith; letter ruling.
901 South Broadway Limited Partnership, Standard Development, LLC, Tax Matters Partner (T.C. Memo. 2021-132) Sec. 170; charitable contributions; deeds of trust in building and multiple lenders; proof mortgages adequately subordinated; facade easement; exclusively for conservation purposes.
Tandra Anne Roberts (T.C. Memo. 2021-131) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; CDP; failure to file return; current with oblications; Form 433-A; financial information.
Herman J. Marino (T.C. Memo. 2021-130) Sec.7623 expenses of detection of underpayment and fraud; whistleblower award; jurisdiction of court; review of analyst's decision.
Bernard D. Holland (T.C. Memo. 2021-129) Sec. 61; 6651; gross income definition; failure to file or pay; retirement plan distribution; Social Security benefits taxable; tax protester arguments.
William Howard Peak (T.C. Memo. 2021-128) Sec. 61; 408; gross income definition; individual retirement accounts; distributions from pension plans not reported; deficiency notice sent after CP12 Notice; deficiency notice within three-year period.
Louis P. Smaldino (T.C. Memo. 2021-127) Sec. 2511; 2512; 2523; transfers in general; valuation of gifts; gift to spouse; indirect gift to trust; monthly payment from trust to donor affect valuation of gift.
Ronald E. Knox and Joan S. Knox (T.C. Memo. 2021-126) Sec. 36B; Premium Tax Credit; failure to report excess advance premium tax credit on return; failure to attache Form 8962, Premium Tax Credit; income in excess of 400 percent of poverty line.
Excelsior Aggregates, LLC, Big Escambia Ventures, LLC, Tax Matters Partner (T.C. Memo. 2021-125) Sec. 6741; procedural requirements; supervisory approval of penalty; initial determination of penalty; penalty under Sec. 6662 or 5595A.
Karla Amburgey and Mary Dutey Amburgey a.k.a. Mary Amburgey (T.C. Memo. 2021-124) Sec. 36B; 6651; 6652; advance premium credit; failure to file or pay; accuracy-related penalty; income above threshold for credit; credit paid to insurance company; late filed return.
Pamela Cashaw (T.C. Memo. 2021-123) Sec. 6672; failure to collect and pay over taxes; trust fund recovery penalty; individual personally responsible; control over finances; signing of checks; determine which vendors and creditors to pay; willfulness.
Tribune Media Company f.k.a. Tribune Company & Affilliates v. Commissioner; Chicago Baseball Holdings, LLC, Northside Entertainment Holdings, LLC, f.k.a. Ricketts Acquisition, LLC, Tax Matters Partner (T.C. Memo. 2021-122) Sec. 707; 752; transactions between partner and partnership; treatment of certain liabilities; disguised sale; distributions to partner; bona fide debt.
Arthur G. Hill, III (T.C. Memo. 2021-121) Sec. 6603; 7481; deposits made to suspend running of interest on potential underpayments; date when Tax Court decision becomes final; motion to redetermine interest; check made to IRS and designated as deposit; interest on excess deposit.
James R. Morris and Lori A. Egbers-Morris (T.C. Memo. 2021-120) Sec. 6651; 6654; failure to file or pay; failure to pay estimated tax; reasonable cause; advice of tax professional.
Ronald M. Goldberg (T.C. Memo. 2021-119) Sec. 6223; 6320; partners bound by actions of partnership; hearing on filing lien notice; challenge to statute of limitations; actual notice of TEFRA litigation; Sec. 6223(a) election; failure to propose collection alternative.
Taryn L. Dodd (T.C. Memo. 2021-118) Sec. 6330; hearing before levy; collection due process; seizure of state tax refund; failure to supply financial information; relief from failure to pay penalty.
John M. Crim (T.C. Memo. 2021-117) Sec. 6330; hearing before levy; collection due process; penalties for abusive tax shelters; challenge of underlying liabilities; period of limitations expired.
Suzanne Jean Mccrory (T.C. Memo. 2021-116) Sec. 7623; expenses of detection of underpayment and fraud; claims that settlement or jury awards not reported as taxable income.
Carl L. Gregory and Leila Gregory (T.C. Memo. 2021-115) Sec. 67; 183; miscellaneous itemized deductions; not for profit activities; hobby losses; boat chartering; list of deductions applied against gross income; itemized vs. miscellaneous itemized deduction.
Robert S. Clark (T.C. Memo. 2021-114) Sec. 61; 6663; gross income definition; fraud penalty; unreported income; bank deposits method; auto body shop; rental properties.
Whistleblower 14377-16w (T.C. Memo. 2021-113) Sec. 7623; expenses of detection of underpayment and fraud; no proceeds collected from information provided; serial whistleblower; petition to continue anonymously.
Michael D. Brown (T.C. Memo. 2021-112) Sec. 6320; 6330; 6512; 7122; hearing on filing lien notice; hearing before levy; limitations on petitions to Tax Court; offer-in-compromise; collection due process; request to apply payment against a specific years' tax.
Daniel Omar Parker and Chantrell Antoine Parker (T.C. Memo. 2021-111) Sec. 162; 274; 280A; 280B; 404; business expenses; business expense substantiation; home office; demolition of structures; contributions by employer to employee's trust; substantiation of contribution to SEP account; cost to demolish a structure; deductions for travel, meals, contemporaneous of auto mileage.
Donna M. Sutherland (T.C. Memo. 2021-110) Sec. 6015; innocent spouse relief; streamlined determination; still married; business role; economic hardship; available funds to pay; request for installment agreement.
Karson C. Kaebel (T.C. Memo. 2021-109) Sec. 6673; 7345; frivolous arguments; revocation or denial of passport; seriously delinquent tax debt certification; deficiency notices; Constitutionality.
Michele Lee Pazden (T.C. Memo. 2021-108); Sec. 6330; hearing before levy; collection due process; failure to timely file; appropriate review of account transcripts and requirements.
Gayle Gaston (T.C. Memo. 2021-107) Sec. 162; 183; 404; business expenses; not-for-profit activities; deductions by employer for contributions to a pension plan; retired but engaged in acting activity.
Wai-Cheung Wilson Chow and Deanne Chow (T.C. Memo. 2021-106) Sec. 7623; expenses of detection of underpayment and fraud; allegations not credible or specific; speculative; taxpayers not given opportunity to supplement claim.
Sherrie L. Webb (T.C. Memo. 2021-105) Sec. 6330; hearing before levy; collection due process; denial of currently not collectible (CNC) status; failure to provide required documentation.
Estate of Charles P. Morgan, Deceased, Roxanna L. Morgan, Personal Representative and Roxanna L. Morgan (T.C. Memo. 2021-104) Sec. 162; 172; 6662; business expenses; net operating loss deduction; accuracy-related penalty; NOL; engaged in trade or business; search for new business; limitation on losses as a result of basis.
?Deborah C. Wood (T.C. Memo. 2021-103) Sec. 911; 6651; 7508; foreign earned income exclusion; failure to file or pay; extension for time as a result of being in combat zone; bona fide resident of Afghanistan; time spent out of U.S.; return to combat zone before return due; contractor for U.S. military.
Irvin Hannis Catlett, Jr., Deceased (T.C. Memo. 2021-102) Sec. 6651; 7454; failure to file or pay; burden of proof in fraud; badges of fraud; unreported income; death of taxpayer; failure to prosecute case; IRS motion to dismiss.
Kidz University, Inc. (T.C. Memo. 2021-101) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; employment tax deposits; employment tax returns; determination not eligible for collection alternatives.
Alexander Bernard Wathen (T.C. Memo. 2021-100) Sec. 61; 162; 274; 6651; 6662; gross income definition; business expenses; business expense substantiation; failure to file or pay; accuracy-related penalty; travel records; documentation; returns filed late; reconstruction of income using bank deposits method.
Amr M. Mohsen (T.C. Memo. 2021-99) Sec. 6330; 6511; hearing before levy; limitations on credit or refund; collection due process; Court lacked jurisdiction to decide claim for refund; requirements for refund not met; payment of tax vs. cash bond; statute of limitations on refunds and credits.
Christian D. Silver (T.C. Memo. 2021-98) Sec. 61; 6673; gross income definition; frivolous return penalty; unreported W-2 income; frivolous penalty not imposed; taxpayer not previously warned.
Jerry R. Abraham and Debra J. Abraham (T.C. Memo. 2021-97) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; offer-in-compromise; income and expense analysis; offer less than reasonable collection potential; lack of special circumstances.
Today's Health Care II LLC (T.C. Memo. 2021-96) Sec. 290E; illegal sale of drugs; ordinary and necessary business deductions disallowed; no violation of Eighth or Sexteenth Amendment to the Constitution.
George S. Harrington (T.C. Memo. 2021-95) Sec. 61; 6501; 6663; 6751; procedural requirements; unreported income; limitations on assessments and collections; fraud penalty; offshore bank accounts; proof of ownership of accounts; badges of fraud; supervisory approval of penalty.
Gloria Ononuju (T.C. Memo. 2021-94) Sec. 4958; 6651; taxes on excess benefit transactions; failure to file or pay; tax-exempt organization; disqualified person; amount to be treated as compensation; failure to file W2; payments not reported on Form 1040; first tier tax; second tier tax.
Frank E. Vennes, Jr. and Kimberly Vennes (T.C. Memo. 2021-93) Sec. 165; 6662; losses; accuracy-related penalty; theft loss deduction; market value of asset; chance of recovery of value; reliance on return preparer; information provided to return preparer.
Estate of Kwang Lee, Deceased, Anthony J. Frese, Executor (T.C. Memo. 2021-92) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; offer-in-compromise rejected; assets distributed by estate.
New World Infrastructure Organization (T.C. Memo. 2021-91) Sec. 501; tax-exempt organizations; activities not qualified for exemption.
Jessee C. Morreale (T.C. Memo. 2021-90) Sec. 7430; recovery of litigation costs; substantially justified position; taxpayer prevailing party; statutory rate.
Jacob Berger and Evelyn R. Berger (T.C. Memo. 2021-89) Sec. 61; 162; 215; 6662; gross income definition; business expenses; alimony; accuracy-related penalty; inconsistency between evidence and testimony; depreciation deductions; Schedule F deductions denied; alimony paid on behalf of another party.
Ernest S. Ryder & Associates, Inc., APLC, et al. (T.C. Memo. 2021-88) Sec. 61; 6651; 6655; 6662; gross income definition; failure to file or pay; failure by corporations to pay estimated tax; accuracy-related penalty; unreported income; unreported dividend income; constructive dividends; multiple bank accounts; fraudulent failure to file.
Blossom Day Care Centers, Inc. (T.C. Memo. 2021-87) Sec. 61; 3401; 6402; 6656; 6662; gross income definition; definitions; mode or time of collection; failure to make deposit of taxes; accuracy-related penalty; unreported income; cash received vs. deposited; workers legally classified as employees; corporate officers; failure to deposit taxes for legally classified employees.
Blossom Day Care Centers, Inc. (T.C. Memo. 2021-86) Sec. 61; 3401; 6402; 6656; 6662; gross income definition; definitions; mode or time of collection; failure to make deposit of taxes; accuracy-related penalty; unreported income; cash received vs. deposited; workers legally classified as employees; corporate officers; failure to deposit taxes for legally classified employees.
Richard C. Mathews (T.C. Memo. 2021-85) Sec. 6213; Tax Court petition; petition not timely; Tax Court jurisdiction.
Francisco Steven Delgado (T.C. Memo. 2021-84) Sec. 61; 7701; gross income definition; definitions; unreported income; self-employment tax; frivolous arguments.
Jay M. Peterfreund (T.C. Memo. 2021-83) Sec. 7623; expenses of detection of underpayments and fraud; statute of limitations lapsed.
Athanasios Pragias and Cynthia Pragias (T.C. Memo. 2021-82) Sec. 6501; limitations on assessments and collections; notice of deficiency timely; six-year limitations period applicable; omission of gross income.
Monique D. Long (T.C. Memo. 2021-81) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; dispute of underlying liability; receipt of notices of deficiency; financial information not provided.
William Geiman (T.C. Memo. 2021-80) Sec. 162; 274; business expenses; business expense substantiation; Tax Court allowed additional expenses over IRS; unreimbursed travel; substantiation by taxpayer.
Engen Robert Nurumbi (T.C. Memo. 2021-79) Sec. 61; 162; 274; 6651; gross income definition; business expenses; business expense substantiation; failure to file or pay; Uber driver; use of vehicle documentation; recordkeeping; failure to separate business from personal expenses.
Alhaji B. Benson (T.C. Memo. 2021-78) Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; contest of underlying liabilities; thorough review by settlement officer.
Jamillah Kamillah Muhammad (T.C. Memo. 2021-77) Sec. 61; 3401; 6673; gross income definition; wages definitions; damages for delay; wages were taxable; frivolous argument.
Michael R. Kelly (T.C. Memo. 2021-76) Sec; 166; 6501; 6662; 6663; bad debts; limitations on assessments and collections; accuracy-related penalty; fraud penalty; bona fide loans; loans vs. distributions; Form 5471.
Monty Ervin (T.C. Memo. 2021-75) Sec. 6651; 6654; failure to file or pay; failure to pay estimated tax; paid by restitution; IRS barred from collection.
Bell Capital Management, Inc. (T.C. Memo. 2021-74) Sec. 3402; 6556; 6663; income tax collected at source; failure to deposit taxes; fraud penalty; in fact employee of corporation; use of offshore employee leasing transactions; chief executive officer.
Whistleblower 10084-16w (T.C. Memo. 2021-73) Sec. 7623; expenses of detection of underpayment and fraud; award denied; IRS did not make adjustments related to the information. Hector I. Garcia and Brenda I. Landrau (T.C. Memo. 2021-72) Sec. 86; 861; 901; Social Security benefits; income from sources within the United States; foreign tax credit; bona fide residents of Puerto Rico; failure to report Social Security benefits; treatment as mathematical error; notice of defiicency not sent.
David Andrew Lufkin (T.C. Memo. 2021-71) Sec. 6330; hearing before levy; collection due process; administrative procedures followed; notice of deficiency valid.
Kannarkat P. Verghese, deceased, Annie P. Verghese, Personal Representative, and Annie P. Verghese (T.C. Memo. 2021-70) Sec. 6330; 6404; hearing before levy; abatement of interest; collection due process; no ministerial or managerial acts constituting unreasonable delay by IRS; Section 6404 inapplicable.
Carol E. Holliday (T.C. Memo. 2021-69) Sec. 61; gross income definition; settlement award for attorney's malpractice includable in income; award not compensation to replace marital property.
ES NPA Holding, LLC, Joseph NPA Investment, LLC, Tax Matters Partner (T.C. Memo. 2021-68) Sec. 721; 6234; nonrecognition of gain or loss on contribution; judicial review of partnership adjustments; receipt of stock in another corporation for services; call option agreement; capital vs. profits interest.
New Capital Fire, Inc. (T.C. Memo. 2021-67) Sec. 368; 1001; mergers; determination of amount of recognition of gain or loss; concealment of facts; equitable estoppel preventing taxpayer from changing return reporting.
Michael Torres (T.C. Memo. 2021-66) Sec. 162; 165; 6651; business expenses; losses; failure to file or pay; theft loss; embezzlement; evidence of claim; ordinary and necessary; funds taken by employee; entitlement to compensation.
Estate of Semone Grossman, Deceased, Richard M. Frome, Preliminary Executor (T.C. Memo. 2021-65) Sec. 2056; bequests to surviving spouse; who is spouse; validity of divorce; rabbinical court; New York law.
Katherine Mason, et al. (T.C. Memo. 2021-64) Sec. 6321; 6330; 7122; lien for taxes; hearing before levy; compromises; collection due process; failure by settlement officer to independently review taxpayer's offer.
Uriah I. Shitrit (T.C. Memo. 2021-63) Sec. 7345; revocation or denial of passport in delinquent taxes; Tax Court jurisdiction; failure to file a return; income reported by third party; substitute return by IRS; dual citizenship; IRS reversal of determination; voluntary cessation exception.
Montgomery-Alabama River, LLC, Parkway South LLC, Tax Matters Partner (T.C. Memo. 2021-62) Sec. 170; charitable contributions; conservation easement; judicial extinguishment; Alabama law.
Vincent J. Fumo (T.C. Memo. 2021-61) Sec. 4958; excess benefit transactions; disqualified person; exempt organization; liability for excise tax.
Estate of Clara M. Morrissette, Deceased, Kenneth Morrissette, Donald J. Morrissette, and John D. Morrissette, Personal Representatives (T.C. Memo. 2021-60) Sec. 2031; 2703; 6662; definition of gross estate; property subject to restrictive agreements; accuracy-related penalty; premiums paid on split-dollar life insurance; bona fide transfers for adequate consideration; bona fide business reason; split-dollar rights.
BRC Operating Company LLC, Bluescape Resource Company LLC, Tax Matters Partner v. Commissioner; Bluescape Resources Company LLC, Bluescape Resources Investors LLC, Tax Matters Partner (T.C. Memo. 2021-59) Sec. 461; year of deduction; drilling costs; cost of goods sold; COGS; accrual method; no sale of goods.
William J. Spain and Idovia A. Spain (T.C. Memo. 2021-58) Sec. 6330; 7502; hearing before levy; petitions to Tax Court; collection due process; filing within 30-day period; no postmark by USPS; proof of timely mailing.
Stanley Battat and Zmira Battat (T.C. Memo. 2021-57) Sec. 6751; procedural requirements; supervisory approval of penalty; Letter 4121 Agreed Examination Report Transmittal as initial determination to impose penalty.
Peter M. Adler (T.C. Memo. 2021-56) Sec. 162; 274; business expenses; business expense substantiation; personal vs. business; documentation; recordkeeping; two separate businesses reported on single Schedule C.
Donald Bailey and Sandra M. Bailey (T.C. Memo. 2021-55) Sec. 162; 280A; 6651; 6662; business expenses; business use of home; failure to file or pay; accuracy-related penalty.
Randy Jenkins; Ira W. Gentry, Jr. and Lynn M. Gentry (T.C. Memo. 2021-54) Sec. 61; 63; 67; 6214; 6501; gross income definition; taxable income definition; 2-percent floor; Tax Court jurisdiction; limitations on collection and assessment; unreported income; corporations as alter egos; federal or state alter-ego law; capital gain taxable to shareholder; tax return not filed; election to itemize made on filed return.
Tikar, Inc. (T.C. Memo. 2021-53) Sec. 501; exempt organizations; proof of serving public interest; furthering exempt purpose.
Andrew Mitchell Berry and Sara Alexine Berry and Andrew Mitchell Berry and Sara Berry (T.C. Memo. 2021-52) Sec. 162; 179; 6651; 6662; business expenses; expensing business assets; failure to file or pay; accuracy-related penalty; failure to prove expenses paid; asset not used for a business purpose. Daniel S. Jacobs (T.C. Memo. 2021-51) Sec. 7430; recovery of litigation costs; attorney's fees; IRS position substantially justified.
Viola Chancellor (T.C. Memo. 2021-50) Sec. 162; 170; 274; business expenses; charitable contributions; business expense substantiation; listed property; meal and entertainment expenses; documentation; recordkeeping.
Marc. Barnes and Anne M. Barnes (T.C. Memo. 2021-49) Sec. 6430; 6330; hearing on filing lien notice; hearing before levy; collection due process; bankruptcy; nondischargeble debt.
Estate of Michael J. Jackson, Deceased, John G. Branca, Co-Executor and John McClain, Co-Executor (T.C. Memo. 2021-48) SEc. 2031; 6662; definition of gross estate; accuracy-related penalty; valuation of estate; intangible assets.
Josef Haghnazarzadeh and Catherine Y. Haghnazarzadeh (T.C. Memo. 2021-47) Sec. 61; gross income definition; unreported income; bank deposits; nontaxable income.
Ronnie S. Baum and Teresa K. Baum (T.C. Memo. 2021-46) Sec. 162; 165; 274; 6651; business expenses; losses; business expense substantiation; failure to file or pay; support for deductions; documentation; recordkeeping; theft loss; fraud claimed in stock purchased in company that declared bankruptcy.
Plentywood Drug, Inc., at al. (T.C. Memo. 2021-45) Sec. 162; 6662; 6664; business expenses; accuracy-related penalty; reasonble cause; excessive rent; fair market value of rent paid; related parties.
Robert Craig Colton and Alina Mazwin (T.C. Memo. 2021-44) Sec. 55; alternative minimum tax; imposition of tax; of tax; miscellaneous itemized deductions disallowed for AMT.
William E. Flynn (T.C. Memo. 2021-43) Sec. 61; gross income definition; underreporting income; bank deposits; IRS reconstruction of income; documentation supporting deposit activity; burden on taxpayer to refute.
Andrew Mitchell Berry and Sara Berry; Ronald Gene Berry and Linda Kathryn Berry (T.C. Memo. 2021-42) Sec. 61; 162; 195; 274; 6662; 6751; 7491; gross income definition; business expenses; business expense substantiation; start-up expenses; accuracy-related penalty; procedural requirements; burden of proof; unreported income; car logs; substantiation of vehicle usage; ordinary and necessary business expenses; supervisory approval of penalty.
Preston Olsen and Elizabeth Olsen (T.C. Memo. 2021-41) Sec. 48; 167; 183; 469; energy credits; depreciation; not-for-profit activities; passive activity losses; solar tax shelter; hobby losse; material participation; documentation; time logs; equipment rental business; activity did not rise to trade or business; any energy credits generated would be passive.
Anna Elise Walton (T.C. Memo. 2021-40) Sec. 6662; 6751; accuracy-related penalty; procedural requirements; failure to report nonemployee compensation; automated underreporter program; reasonable exception; supervisory approval of penalty.
John K. Crandall and Nives M. Crandall (T.C. Memo. 2021-39) Sec. 7121; 6662; closing agreements; accuracy-related penalty; foreign tax credit; foreign source income; closing agreement precluding deficiency and penalty.
Purple Heart Patient Center, Inc. (T.C. Memo. 2021-38) Sec. 61; 6662; gross income definition; accuracy-related penalty; bank deposits analysis; Cohan rule; substantiation of expenditures; cost of goods sold; destruction of records; unreported income.
Leon Max (T.C. Memo. 2021-37) Sec. 41; 174; credit for research activities; research and experimental expenditures; qualified research; tests examined and considered.
American Limousines, Inc. (T.C. Memo. 2021-36) Sec. 6159; installment agreement; rejected for inability to make the proposed payments; collection by levy; no currently not collectible status; employment taxes.
Linda J. Martin and John A Martin (T.C. Memo. 2021-35) Sec. 162; 172; 280A; 6651; 6662; business expenses; net operating losses; business use of home; failure to file or pay; accuracy-related penalty; home office; NOL; unreported income; bank deposits analysis; proof of NOL; NOLs in bankruptcy; ordinary and necessary business expenses.
Thomas L. Siebert and Deborah S. Siebert (T.C. Memo. 2021-34) Sec. 6330; hearing before levy; collection due process; installment agreement; IA; offer-in-compromise; OIC; currently not collectible status; CNC; reasonable collection potential; RCP; abuse of discretion by IRS; noncompliance; dissipated assets; payment to relative of unsecured loan; use of funds for ordinary living expenses.
John A. Catania (T.C. Memo. 2021-33) Sec. 72; distributions from qualified plans; premature distribution; penalty tax.
Lateesa Ward; Ward & Ward Company (T.C. Memo. 2021-32) Sec. 61; 108; 162; 274; 3404; gross income definition; cancellation of debt income; business expenses; business expense substantiation; employer's responsibility to withhold; insolvency; discharge of debt; business purpose of expenses; employment taxes; shareholder considered employee of S corporation.
Brian E. Harriss (T.C. Memo. 2021-31) Sec. 61; 72; 6212; gross income definition; distributions from qualified plans; notice of deficiency; premature distributions; unreported distribution from pension plan; validity of deficiency notice challenged.
Caylor Land & Development, Inc., et al. (T.C. Memo. 2021-30) Sec. 162; 831; 6662; business expenses; tax on insurance companies other than life insurance; accuracy-related penalty; captive insurance arrangement; distribution of risks; not in insurance business.
Sheila Ann Smith (T.C. Memo. 2021-29) Sec. 6330; 6673; 6702; hearing before levy; penalty for delay; frivolous returns; collection due process; zero returns; failure to pay penalties.
Clarence J. Mathews (T.C. Memo. 2021-28) Sec. 262; 6662; personal expenses; accuracy-related penalty; Schedule C expenses disallowed; documentation; lack of income on Schedule C; business purpose of expenses.
Luke Joseph Chiarelli (T.C. Memo. 2021-27) Sec. 170; 6662; charitable contribution; accuracy-related penalty; contribution of noncash property; substantiation; documentation; receipts offered lacked sufficent detail.
Duane Pankratz (T.C. Memo. 2021-26) Sec. 170; 6662; 6664; charitable contributions; accuracy-related penalty; reasonable cause; lack of appraisal; failure to review return; reliance on qualified professional.
Joseph A. Gallegos and Joy K. Gallegos (T.C. Memo. 2021-25) Sec. 162; 183; business expenses; not-for-profit activities; hobby losses; activity resulted in personal expenses put on Schedule C; factors considered in determining activity engaged in for profit.
Craig L. Galloway (T.C. Memo. 2021-24) Sec. 6320; 6330; hearing before filing lien notice; hearing before levy; offer-in-compromise; factors balanced in filing of notice of federal tax lien.
Konstantin Anikeev and Nadezhda Anikeev (T.C. Memo. 2021-23) Sec. 61; gross income definition; cash rewards from use of credit cards included in income; difference from rebate noted.
Desert Organic Solutions (T.C. Memo. 2021-22) Sec. 280E; illegal sale of drugs; marijuana; no separate trade or business; minimal non-drug business.
William Allen Llanos (T.C. Memo. 2021-21) Sec. 6330; 6702; hearing before levy; procedural requirements; collection due process; supervisory approval of penalty; invitation to correct frivolous return not initial determination of penalty.
Vikki L. Rogers, Petitioner, and Brian D. Rogers, Intervenor (T.C. Memo. 2021-20) Sec. 6015; innocent spouse relief; knowledge of understated tax; participation in operation of joint owned limited liability company; factors weighed for relief.
Friendship Creative Printers Inc. (T.C. Memo. 2021-19) Sec. 6651; 6656; failure to file or pay; failure to make deposit of taxes; employment taxes; Form 941.
Debra Jean Blum (T.C. Memo. 2021-18) Sec. 61; 104; gross income definition; damage awards and sick pay; no physical injuries sustained; recovery of capital; inclusion in income.
Estate of Miriam M. Warne, Deceased, William R. Warne and Thomas H. Warne, Co-Executors (T.C. Memo. 2021-17) Sec. 2031; 2055; 2512; 6651; definition of gross estate; transfers for public, charitable and religious uses; valuation of gifts; failure to file or pay; valuation of ground leases; discounts for lack of control and marketability; determiniation of value.
Don Kramer and Lela Arabuli; Don Kramer (T.C. Memo. 2021-16) Tax Court Rule 123(a); Sec. 6651; 6662; 6663; failure to file or pay; accuracy-related penalty; civil fraud; IRS presumption of correctness; redetermination.
Little Sandy Coal Company, Inc. (T.C. Memo. 2021-15) Sec. 38; 41; general business credit; credit for increasing research activities; process of experimentation; shipbuildng; 80 percent of research must be elements of a process of experimentation.
Complex Media, Inc. (T.C. Memo. 2021-14) Sec. 197; amortization of intangibles; disavow transactions; step transaction doctrine; partnership recognition of gain.
BM Construction (T.C. Memo. 2021-13) Sec 6330; hearing before levy; collection due process; penalty for failure to issue Forms 1099-MISC to subcontractors; proof of mailing of notice of determination by IRS.
Kevin A. Sells, et al. (T.C. Memo. 2021-12) Sec. 170; 6662; charitable contribution; accuracy-related penalty; conservation easement; gross misstatement penalty; cutting of timber not a conservation purpose.
Stephen Whatley aned Lucile M. Whatley (T.C. Memo. 2021-11) Sec. 162; 183; business expenses; not-for-profit activities; hobby losses; cattle farm; factors weighed.
Dana Ray Reynolds (T.C. Memo. 2021-10) Sec. 6201; 6320; 6330; assessment authority; hearing before filing lien notice; hearing beforr levy; collection due process; partial payment installment agreement; request for currently not collectible status; restitution based assessment; unreported income.
William Brucke Costello and Maritz Legarcie (T.C. Memo. 2021-9) Sec. 195; 6651; 6682; startup expenses; failure to file or pay; accuracy-related penalty; farming activities did not progress beyond investigation phase; trade or business; property held for rental; property not in condition for rental.
Aspro, Inc. (T.C. Memo. 2021-8) Sec. 162; business expenses; management fees paid to shareholders; distributions; basis of fees paid; C corporation.
Meredith Yvette James (T.C. Memo. 2021-7) Sec. 6013; 6015; married filing joint; innocent spouse relief; joint return invalid; not married at filing.
Aaron G. Filler (T.C. Memo. 2021-6) Sec. 172; 1235; 6662; 6664; net operating loss; sale or exchange of patents; accuracy-related pealty; reasonable cause; licensing of patent; ordinary income vs. capital gain; transfer to related person.
Michael Hohl and Jennifer Parker Hohl; Braden B. Blake and Kristen S. Blake (T.C. Memo. 2021-5) Sec. 61; gross income definition; income from the discharge of the debt of a partnership; loans to partnership vs. equity contributions.
Michael J. Boettcher and Katherine H. Boettcher (T.C. Memo. 2021-4) Sec. 6330; hearing before levy; collection due process; remand to Office of Appeals for additional information; installment agreement request; settlement officer's analysis questioned.
Patrick S. Kennedy (T.C. Memo. 2021-3) Sec. 4976; 7623; taxes on funded welfare benefit plans; whistleblower awards; VEBA; excise taxes; summary judgment; claim of amounts collected in bankruptcy action; timing of claim and bankruptcy.
Patrick C. Kelley (T.C. Memo. 2021-2) Sec. 86; Social Security benefits; taxability.
Edward J. Tangel and Beatrice C. Tangel (T.C. Memo. 2021-1). Sec. 41; credit for increasing research activities; pass-through by S corporation; insufficient documentation; activities paid for by third party.

 

Summary Opinions

Nowran Gopi (T.C. Summary Opinion 2021-41) Sec. 1; 24; 32; 151; individuial income tax; child tax credit; earned income tax credit; personal exemption; head of household status; dependency exemption; granddaughter; father claimed exemption for same child; qualifying child.
Donald G. Swyers (T.C. Summary Opinion 2021-40) Sec. 162; 170; 274; 6662; business expenses; charitable contributions; business expense substantiation; accuracy-related penalty; unreimbursed employee business expenses; substantiation of vehicle expenses; recordkeeping; documentation; Schedule C expenses; employee vs. independent contractor.
James Forrest Willetts (T.C. Summary Opinion 2021-39) Sec. 6511; limitations on credit or refund; timely extension request filed; potential identity theft.
Howard E. Steele and Tracy M. Steele (T.C. Summary Opinion 2021-38) Sec. 162; 274; business expenses; business expense substantiation; documentation not complete for some purchases; vehicle expenses; capital expenditures on rental property not documented.
Forrest Crawley and Shawna Crawley (T.C. Summary Opinion 2021-37) Sec. 217; 274; moving expenses; business expense substantiation; taxpayers' testimony credible; records lost; Cohan rule.
Tara K. Tobin, Petitioner, and Jeffrey Tobin, Intervenor (T.C. Summary Opinion 2021-36) Sec. 6015; innocent spouse relief; actual knowledge; unreported income; threshold requirements satisfied.
Anthony J. Todisco, Jr., and April J. Gonzales; April J. Gonzales F.K.A. April J. Todisco (T.C. Summary Opinion 2021-35) Sec. 6015; innocent spouse relief; knowledge of understatements; equitable relief; requirements of Sec. 6015(b).
Maria Isabel Goode and James T. Goode (T.C. Summary Opinion 2021-34) Sec. 6015; innocent spouse relief; knowledge of income; cancellation of debt; economic hardship; knowledge of underpayment.
Rebecca A. Tressler (T.C. Summary Opinion 2021-33) Sec. 104; damage awards and sick pay; no portion of settlement designated as paid for physical injuries or sickness; substantiation of payments for medication and psychotherapy; portion of settlement excluded which related to medical bills.
Avito M. Vasquez (T.C. Summary Opinion 2021-32) Sec. 162; 274; business expenses; business expense substantiation; unreimbursed business expenses; tax home; travel away from home; substantiation of business mileage.
Denise Sadjian Curcio (T.C. Summary Opinion 2021-31) Sec. 6015; innocent spouse relief; knowledge tax would not be paid by spouse; economic hardship.
Daniel P. Whoriskey and Leigh L. Whoriskey (T.C. Summary Opinion 2021-30) Sec. 163; 469; interest expense; passive activity losses; claimed interest expense vs. reported by third party; qualified residence vs. rental property; real estate professionals; passive activity loss limitation.
Jessica Lynn Grady a.k.a. Jessica Lynn Gans (T.C. Summary Opinion 2021-29) Sec. 6015; innocent spouse relief; spouse's failure to file; equitable relief.
Earl R. Detwiler and Diana M. Detwiler (T.C. Summary Opintion 2021-28) Sec. 162; 213; 274; business expenses; medical expenses; business expense substantiation; unreimbursed business expenses; documentation; recordkeeping.
David Evan Ushio and Judith S. Ushio (T.C. Summary Opinion 2021-27) Sec. 1244; 6662; losses for small business stock; accuracy-related penalty; requirements; $1 million maximum capitalization; documentation; substantiation; recordkeeping.
Carol Denise Griffin T.C. Summary Opinion 2021-26) Sec. 24; 32; 152; child tax credit; earned income tax credit; dependent definition; residence requirement; qualifying child; relationship, support, ate tests met.
Hyrum Mckay Bates and Katherine Call Bates (T.C. Summary Opinion 2021-25) Sec. 6330; hearing before levy; collection due process; failure to provide financial information and documentation.
Dion E. Monroe and Kim M. Monroe (T.C. Summary Opinion 2021-24) Sec. 61; 162; 274; 6662; gross income definition; business expenses; business expense substantiation; accuracy-related penalty; W-2 income reported on Schedule C; deduction of unreimbursed business expenses on Schedule A; years 2014 and 2015.
documentation; recordkeeping. Leila Saedian (T.C. Summary Opinion 2021-23) Sec. 162; 170; 6662; business expenses; charitable contributions; accuracy-related penalty; partial deduction for home office; substantiation of charitable contributions; failure to seek reimbursement from employer; deduction for portion of internet and cell phone.
Tondalaya Gamble and Ronald Jamison (T.C. Summary Opinion 2021-22) Sec. 162; 165; 6662; 6664; business expenses; losses; accuracy-related penalty; reasonable cause; carrying on a trade or business; relationship of expenses to S corporation; gambling income and losses; substantiation of gambling losses; contemporaneous records; reasonable cause; reliance on tax preparer.
Angela West (T.C. Summary Opinion 2021-21) Sec. 162; business expenses; travel expenses; meals; away from home; principal place of employment; work as employee; job for indefinite period of time.
Maher Bassily and Nermine Bassily (T.C. Summary Opinion 2021-20) Sec. 61; 901; gross income definition; foreign tax credit; taxability of foreign source income; disallowance of foreign tax credit.
Sam Fagenboym and Oksana Fagenboym (T.C. Summary Opinion 2021-19) Sec. 1363; 6001; effects of S election; required records; S corporation expenses; substantiation; recordkeeping; documentation; reconstruction; Cohan rule.
Paul Warque and Marie Warque (T.C. Summary Opinion 2021-18) Sec. 162; 262; business expenses; personal expenses; unreimbursed business expenses; travelling expenses; personal preference for living location.
Todd A. Minarich and Judy A. Minarich (T.C. Summary Opinion 2021-17) Sec. 162; 6662; business expenses; accuracy-related penalty; rental property; no depreciation schedule; no support for basis; recordkeeping; substantiation; documentation.
Travis Bridges (T.C. Summary Opinion 2021-16) Sec. 162; 6662; business expenses; accuracy-related penalty; recordkeeping; documentation, substantiation.
John Legoski (T.C. Summary Opinion 2021-15) Sec. 162; 6662; business exepnses; accuracy-related penalty; recordkeeping; documentation; substantiation of cost of goods sold.
Maria Claudia Ginos (T.C. Summary Opinion 2021-14) Sec. 6015; innocent spouse relief; streamlined relief; factors favoring relief; economic hardship.
Connie Sue Heston (T.C. Summary Opinion 2021-13) Sec. 36B; Premium Tax Credit; advance credit; PTC; APTC; Social Security Disability Benefits Insurance; modified adjusted gross income; MAGI; lump-sum social security disability benefit included in modified adjusted gross income for premium credit.
Nickels B. Peeples (T.C. Summary Opinion 2021-12) Sec.162; 274; business expenses; busienss expense substantiation; unreimbursed employee business expenses; listed property; documentation; recordkeeping.
Fred Lavat Frederick-Bey and Monica Noble (T.C. Summary Opinion 2021-11) Se. 162; 262; business expenses; personal expenses; ordinary and necessary; Schedule C.
Richard Alan Post and Janices Lorraine Post (T.C. Summary Opinion 2021-10) Sec. 162; 274; business expenses; business expense substantiation; unreimbursed employee business expenses; ordinary and necessary; reimbursed by employer.
Jennevieve Marie Fletcher (T.C. Summary Opinion 2021-9) Sec. 86; Social Security benefits; taxability; gross income; excess benefits; requirement to repay.
Ivan T. Clover and Esther O. Clover (T.C. Summary Opinion 2021-8) Sec. 6330; hearing before levy; collection due process; failure to pay; levy action; no evidence of challenge of liability.
Abrahan Pichardo and Carolina Pichardo (T.C. Summary Opinion 2021-7) Sec. 25A; 67; 162; American Opportunity Tax Credit; miscellaneous itemized deductions; business expenses; unreimbursed business expenses; 2-percent floor; reimbursement not sought; less than half-time student.
Alan Dexter Wenk (T.C. Summary Opinion 2021-6) Sec. 72; 402; qualified plan distributions; taxability of beneficiary of employee's trust; distribution taxable; addition to tax for premature distribution.
Michael Hohl and Jennifer Parker Hohl; Braden B. Blake and Kristen S. Blake (T.C Summary Opinion 2021-5) Sec. 61; gross income definition; cancellation of debt income; discharge of partnership debt; guaranteed payments; loans to partnership subsequently treated as contributions to capital; funds considered loans by Tax Court.
Terry T. Brown, Sr. (T.C. Summary Opinion 2021-4) 61; 162; 274; 408; 6662; gross income definition; business expenses; business expense substantiation; individual retirement accounts; accuracy-related penalty; unreported distributions from retirement account; disallowed Schedule C expenses; real estate professional; documentation; recordkeeping.
Akeem Adebayo Soboyede (T.C. Summary Opinion 2021-3) Sec. 162; 274; business expenses; business expense substantiation; lodging expenses; away from home; temporary vs. indefinite; contemporaneous record; recordkeeping; documentation.
Dianne S. Hairston and Steve R. Hairston (T.C. Summary Opinion 2021-2) Sec. 61; 86; gross income definition; Social Security income; Social Security disability income; workers' compensation payments.
Paul B. Bruneau and Karen L. Bruneau (T.C. Summary Opinion 2021-1) Sec. 61; 167; 274; 6662; gross income definition; depreciation; business expense substantiation; accuracy-related penalty; Cohan rule; unreported income; insufficient to substantiate basis in depreciable property; substantiation of travel expenses; log or diary; reliance on professional; failure to review returns.

 


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