Small Business Taxes & Management

Tax Court Cases--2024


Small Business Taxes & ManagementTM--Copyright 2024, A/N Group, Inc.

 

Below is a list of the 2024 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 revised 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--2023
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

 

New Additions - Week Ended February 17, 2024

Tax Court Cases

None

 

Memorandum Decisions

Donald Ecret and Kristen Ecret (T.C. Memo. 2024-23) Sec. 86; Social Security benefits; social security disability benefits and social security benefits; maximum nontazable amount; average current earnings; ACE.
Whistleblower 14376-16W (T.C. Memo. 2024-22) Sec. 7623; expenses of detection of underpayment and fraud; denial of award; target filed delinquent and amended returns; no bad faith on Whistleblower Office.
Acqis Technology, Inc. and Colsolidated Subsidiary (T.C. Memo. 2024-21) Sec. 61; 6501; 6662; gross income definition; limitations on assessment and collection; accuracy-related penalty; settlement for patent infringement; inclusion of award in income; contributions to capital; purchase agreement of shares sham transaction; intention of other party; transaction deemed sham.

 

Summary Opinions

None

 

Cumulative Cases - 2024

Tax Court Cases

Sydney Ann Chaney Thomas (162 T.C. No. 2) Sec. 6015 innocent spouse relief; failure to show economic hardship; enjoyment of vacations while tax liabilities not discharged.
Douglas Dodson and Rebecca Dodson (162 T.C. No. 1) Sec. 6213; petition to Tax Court; deadline for filing petition on deficiency notice incorrect; second notice sent; date on first notice governs filing deadline.

 

Memorandum Decisions

Donald Ecret and Kristen Ecret (T.C. Memo. 2024-23) Sec. 86; Social Security benefits; social security disability benefits and social security benefits; maximum nontazable amount; average current earnings; ACE.
Whistleblower 14376-16W (T.C. Memo. 2024-22) Sec. 7623; expenses of detection of underpayment and fraud; denial of award; target filed delinquent and amended returns; no bad faith on Whistleblower Office.
Acqis Technology, Inc. and Colsolidated Subsidiary (T.C. Memo. 2024-21) Sec. 61; 6501; 6662; gross income definition; limitations on assessment and collection; accuracy-related penalty; settlement for patent infringement; inclusion of award in income; contributions to capital; purchase agreement of shares sham transaction; intention of other party; transaction deemed sham.
Susan D. Turner (T.C. Memo. 2024-20) Sec. 2, 32; 152; head of household; earned income credit; dependent definition; qualifying child; principal place of abode for more than half the tax year.
Christopher Crumedy (T.C. Memo. 2024-19) Sec. 6330; 6702; hearing before levy; penalty for frivolous returns; challenge of liability; failure to receive notice of deficiency; failure to raise issue during hearing.
Joseph Anthony Martino, Jr. (T.C. Memo. 2024-18) Sec. 71; alimony; payments not alimony but property settlement; installment payments on property settlement; documents created over 10-year period.
Justin C. Cloar (T.C. Memo. 2024-17) Sec. 6330; hearing before lefy; collection due process; CDP; rejection of offer in compromise; claim of zero monthly earnings; IRS arguement that taxpayer had potential to be employed again.
Lonnie Wayne Hubbard (T.C. Memo. 2024-16) Sec. 61; 6651; gross income definition; failure to file or pay; contructive receipt from individual retirement account; IRA account forfeited to government; constructive receipt of funds by receiving an economic benefit; taxpayer should have known forfeiture of IRA would produce income.
Christopher Meyer, Transferee (T.C. Memo. 2024-15) Sec. 6901; transferred assets; stock sale reclassified by IRS as asset sale and liquidating distributing: IRS precluded by statute of limitations; judicially estopped.
Paulette Thompson and Johnnie L. Thompson v. Commissioner; Paulette Thompson (T.C. Memo. 2024-14) Sec. 61; 162; 6651; 6654; gross income definition; business exenses; failure to file or pay; failure to pay estimated tax; cancellation of debt income; COD; unreported income; agricultural program payment income; business purpose of expenses.
Bernard T.Swift, Jr. and Kathy L. Swift (T.C. Memo. 2024-13) Sec. 162; 831; 6662; business expenses; tax on insurance companies; accuracy-related penalty; microcaptive insurance companies; deductions for legal and professional expenses.
Cynthia L. Huffman and Estate of Chet S. Huffman, Deceased, Cynthia L. Huffman, Executor, et al. (T.C. Memo. 2024-12) Sec. 6662; accuracy-related penalty, gift tax; sale of shares in a corporation to son from exercised options; reliance on professional; reasonable cause.
Essel Eyewear, Inc. (T.C. Memo. 2024-11) Sec. 162; 6662; business expenses; accuracy-related penalty; reconstruction of income; failure to maintain books and records; deemed admissions; substantiation; recordkeeping; documentation.
Stephanie Murrin (T.C. Memo. 2024-10) Sec. 6501; limitations on assessments and collections; fraudulent return by preparer with intent to evade tax; statute of limitations not applicable.
Michael W. Aubin and Kerry A. Aubin (T.C. Memo. 2024-9); Sec. 7121; closing agreements; enforceability; delegation of power by IRS.
Estate of Thomas H. Fry, Deceased, Ruth M. Fry, Personal Representative, and Ruth M. Fry (T.C. Memo. 2024-8) Sec. 1366; 6662; pass-through to shareholders; accuracy-related p0enalty; transfers to S corporation; interests in equity; sufficient stock basis for deducting flow-through losses.
Saul Bradley (T.C. Memo. 2024-7) Sec. 6330; hearing before levy; collection due process; proof of mailing of deficiency notice; currently not collectile (CNC) status denied.
Clair R. Couturier, Jr. (T.C. Memo. 2024-6) Sec. 4973; 6751; tax on excess contributions; procedural requirements; excess contribution "penalty" was a tax and not a penalty; supervisory approval not needed for additional tax.
Christopher R. Pangelina (T.C. Memo. 2024-5) Sec. 6020; 6651; 6662; returns prepared by IRS; failure to file or pay; accuracy-related penalty; substitute for return.
William M. Hefley and Aimee J. Hefley (T.C . Memo. 2024-4) Sec. 162; 6662; 6751; business expenses; accuracy-related penalty; procedural requirements; approval of supervisor for penalty; unreported income not addressed by taxpayers; substantiation of deductions.
William E. Frazier and Mary A. Frazier, et al. (T.C. Memo. 2024-3) Sec. 162; 6214; 6651; 6662; business expenses; determinations by Tax Court; failure to file or pay; accuracy-related penalty; evidence of actual source of payment; related entities; issue raised on brief; lack of warning to taxpayers; reasonable cause for failure to file; threshold for accuracy-related penalty not met.
Terence J. Keating and Janet D. Keating, et al. (T.C. Memo. 2024-2) Sec. 162; 301; 316; 831; 953; 6662; business expensess; corporate distributions of property; what is a dividend; tax on insurance companies; insurance income; aaccuracy-related penalty; microcaptive arrangement; qualification as insurance company; distributions as dividend incoem.
Jesse Alvarado and Estate of Maria De Lourdes Velasquez, Deceased, Jesse Alvarado, Special Administrator (T.C. Memo. 2024-1) Sec. 61; 6651; 6662; 6664; gross income definition; failure o file or pay; accuracy-related penalty; civil fraud penalty; recordkeeping; documentation; cost of goods sold estimated; reasonable cause exception.

 

Summary Opinions

 


Copyright 2024 by A/N Group, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is distributed with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The information is not necessarily a complete summary of all materials on the subject.--ISSN 1089-1536


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--Last Update 02/17/24