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

Tax Court Cases

John F. Carter (163 T.C. No. 6) Sec. 7623; expenses of detection of underpayments and fraud; bankruptcy of whistleblower did not automatically stay a whistleblower case filed by taxpayer.

Memorandum Decisions

Ruben T. Varela (T.C. Memo. 2024-92) Sec. 6330; 6702; hearing before levy; penalty for frivolous returns; collection due process; CDP; return reporting zero wages or income.

Summary Opinions

James Michael Warren (Summary Opinion 2024-20) Sec. 469; 6662; passive ctivity losses; accuracy-related penalty; real estate professional; documentation as to hours spent in real estate; full-time employee at first job.
Yelena Tolstov (Summary Opinion 2024-19) Sec. 165; 6662; losses; accuracy-related penalty; substantiation of gambling losses.

Tax Court Cases

John F. Carter (163 T.C. No. 6) Sec. 7623; expenses of detection of underpayments and fraud; bankruptcy of whistleblower did not automatically stay a whistleblower case filed by taxpayer.
Bruce E. McDougall, Donor, et al. (163 T.C. No. 5) Sec. 2501; 2511; 2519; imposition of gift tax; transfers in general; dispositions of life estates; agreement to terminate QTIP (qualified terminable interest property) distributing assets to surviving spouse; not taxable gift; transfer of assets for note; no deemed gift.
Varian Medical Systems (163 T.C. No. 4) Sec. 78; 245A; foreign dividend gross up; deduction for foreign source dividends received by certain domestic corporations; participation exemption dividends received deduction; DRD; date mismatch in law.
J.E. Ryckman (163 T.C. No. 3) Sec. 6320; 6330; hearing on filing lien notice; collection due process hearing; CDP; jurisdiction; rights to be heard in Tax Court; Canadian tax liability; mutual collection assistance request.
Catherine L. Larosa (163 T.C. No. 2) SEc. 6015; innocent spouse relief; erroneous refund of interest; taxpayer sought equitable relief; did not give rise to unpaid tax.
Edward L. Berman and Ellen L. Berman; Annie Berman (163 T.C. No. 1) Sec. 453; 1042; installment sale method; nonrecognition of gain; sale of stock to employee stock ownership plan; ESOP; deferral of gain; Swc. 1042 election to defer gain; qualified replacement property.
Belagio Fine Jewelry, Inc. (162 T.C. No. 11) Sec. 7436; determination of employment taxes; pewtition to Tax Court mailed via service not a designated private delivery service; petitioner claimed deadline is a nonjurisdictional claim processing rule subject to equitable tolling.
SN Worthington Holdings LLC f.k.a. Jacobs West St. Clair Acquisition LLC, MM Worthington Inc., Tax Matters Partner (162 T.C. No. 10) Sec. 6221; determination at partnership level; LLC taxed as partnership; BBA procedures; Bipartisan Budget Act of 2015; sufficient assets to pay potential underpayment.
Estate of Sally J. Anenberg, Donor, Deceased, Steven B. Anenberg, Executor and Special Administrator (162 T.C. No. 9) Sec. 2501; 2519; imposition of gift tax; disposition of life estates; termination of qualified terminable interest property; QTIP; relinquishment of interest in trusts; deemed transfer of remainder interests in trusts; distributions not a gift.
Raju J. Mukhi (162 T.C. No. 8) Sec. 6038; 6677; 6330; information reporting with respect to certain foreign corporations; failure to file information with respect to certain foreign trusts; hearing before levy; collection due process; CDP; penalties not fines; eight amendment excessive fines clause; protecting revenue and reimbursement of government of investigation; IRS authority under Section 6038.
Mohamed K. Abdo and Fardowsa J. Farah (162 T.C. No. 7) Sec. 7508A: authority to postpone certain deadlines; automatic postponement; Covid-19 pandemic; non-pension-related time-sensitive act.
Valley PLark Ranch, LLC, Reed Oppenheimer, Tax Matters Partner (162 T.C. No. 6) Sec. 170; charitable contribution; qualified conservation easement; protected in perpetuity; statute procedurally invalid under the Administrative Procedure Act and that the deed therefore need not comply with its requirements.
Paul Andrew Frutiger (162 T.C. No. 5) Sec. 6015; innocent spouse relief; jurisdiction; 90-day deadline for filing petition; statute clear.
Clair R. Couturier (162 T.C. No. 4) Sec. 4973; 6501; excess IRA contributions; limitation on assessment and collection; no retroactive application of Sec. 6501 penalty.
23rd Chelsea Associates, L.L.C., Related 23rd Chelsea Associates, L.L.C., Tax Matters Partner (162 T.C. No 3) Sec. 42; low income housing credit; financing with tax-exempt bonds; inclusion of financing costs in eligible basis.
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

Ruben T. Varela (T.C. Memo. 2024-92) Sec. 6330; 6702; hearing before levy; penalty for frivolous returns; collection due process; CDP; return reporting zero wages or income.
Ralph M. Ottuso (T.C. Memo. 2024-91) Sec. 162; 167; 179; 274; 6651; business expenses; depreciation; expensing business assets; business expense substantiation; failure to file or pay; substantiation of gas expenses; auto recordkeeping; no proof for exclusive use for business purposes; late filed return could not make Sec. 179 election.
Estate of Anne Milner Fields, Deceased, Bryan K. Milner, Executor (T.C. Memo. 2024-90) Sec. 2031; 2036; 6662; definition of gross estate; transfers with retained life estate; accuracy-telated penalty; family limited partnership; decedent had right to all income from asset transferred.
Estate of Larry Becker, Deceased, Gary C. Becker, Executor (T.C. Memo 2024-89) Sec. 2031; 2042; definition of gross estate; life insurance owned by irrevocable trust; original purchaser of life insurance; proceeds of trust payable to trust beneficiaries; IRS argued step transacion rule.
Mark Feathers and Natalie E. Feathers (T.C. Memo. 2024-88) Sec. 6214; 6651; 6662; determinations by Tax Court; failure to file or pay; accuracy-related penalty; fees paid to shareholder of corporation were taxable income; deemed to have admitted liability for accuracy-related penalty.
Royalty Management Insurance Company, Ltd.; John B. Sheperd and Andrea Sheperd (T.C. Memo. 2024-87) Sec. 162; 831; 6662; business expenses; tax on insurance companies; acuracy-related penalty; not a bona-fide insurance company; expenses of separate entity not deductible as insurance premiums.
John K. Pak; Kyung Kum Pak (T.C. Memo. 2024-86) Sec. 162; 167; business expenses; depreciation; documentation; substantiation; checks made to cash; work of CPA as support for expenses; documentation of basis in property; contract labor expenses; Cohan rule.
Scenic Trust, Dennis Simpson, Special Trustee; Dennis Lee Simpson (T.C. Memo. 2024-85) Sec. 6501; 6651; fraud; failure to file or pay; fraud not shown; badges not sufficient; extended period of limitations did not apply; failure to show taxpayer fraudulently failed to file return.
Jeffrey D. Hoyal and Lori D. Hoyal; Crater Lake Trust, Keri Couvrette, Trustee (T.C. Memo. 2024-84) Sec. Sec. 6501; 7454; limitations on assessments and collection; fraud; fraud not proved; statute of limitations; deficiency notices issued too late.
Karen Veeraswamy (T.C. Memo. 2024-83) Sec. 1361; 6651; S corporation definition; failure to file or pay; shareholder to report proportionate share of S corporations's net income; liable for return filing; reliance on accountant's advice.
Katherine J. Kalk (T.C. Memo. 2024-82) Sec. 162; 165; 274; business expenses; losses; business expense substantiation; cost of goods sold; documentation; recordkeeping; lack of documentation; auto recordkeeping; business purpose of expenses; travel expenses; meals; gambling losses.
James E. Keith and Julie Keith (T.C. Memo. 2024-81) Sec. 6330; hearing before levy; collection due process; CDP; errors by IRS and taxpayer; remand to office of Appeals.
Estate of Ralph W. Baumgardner, Jr., Deceased, Patricia L. Baumgardner, Personal Representative, and Patricia L. Baumgardner (T.C. Memo. 2024-80) Sec. 6330; hearing before levy; collectiion due process; CDP; rejection by IRS of offer-in-compromise; offer less than reasonable collection potential; arguments considered by settlement officer.
Lawrence Leroy Henry (T.C. Memo. 2024-79) Sec. 162; 274; 280A; 280F; 6651; 6654; business expenses; business expenses substantiation; home office deduction; luxury autos; failure to file or pay; failure to pay estimated tax; recordkeeping; documentation; listed property; travel, meals and entertainment.
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 (T.C. Memo. 2024-78) Sec. 475; 704; 1446; mark to market accounting method for securities dealers; partner's distributive share; withholding on foreign parnters' share of effectively connected income; definition of securities; capital interests in the partnership; foreign special purpose vehicles.
James J. Maggard and Szu-Yi Chang (T.C. Memo. 2024-77) Sec. 1361; dispropportionate distributions of stock not fatal to S corporation status.
Gregory R. Schnackel and Laura B. Schnackel (T.C. Memo. 2024-76) Sec. 162; 167; 172; 179; 274; 6015; 6662; business expenses; depreciation; net operating loss; expensing business assets; business expenses substantiation; innocent spouse relief; accuracy-related penalty; business purpose of condominium rental expense; business purpose of vehicle not substantiated; substantiation of net operating loss; wife's involvement in husband's business activity.
Robert Dean Mazotti and Debra Lea Jones-Mazotti (T.C. Memo. 2024-75) Sec. 183; 6662; not for profit activities; accuracy-related penalty; hobby losses; writing and research activities; failed to keep books and records; extended period of losses; personal element.
Whistleblower 6544-19W (T.C. Memo. 2024-74) Sec. 7023; expenses of detection of underpayment and fraud; award at 22 rather than 30 percent of collected proceeds; not abuse of discretion.
Oconee Landing Property, LLC, Oconee Landing Investors, LLC, Tax Matters Partner (T.C. Memo. 2024-73) Sec. 6662; accuracy-related penalty; no stacking rule; failure to substantiate basis in property donated to charity; adequate records; substantiation; documentation; failure to secure a qualified appraisal prima facia evidence of negligence.
Corning Place Ohio, LLC, Corning Place Ohio investment, LLC, Tax Matters Partner (T.C. Memo. 2024-72) Sec. 162; 170; 6662; business expenses; charitable contributions; accuracy-related penalty; disregarded entity; deduction not allowed to partnership; net rental real estate loss claim denied.
Kenneth Steven Tuma, Sr., and Deborah Ann Tuma (T.C. Memo. 2024-71) Sec. 61; 72; 86; 104; gross income definition; distributions from qualified plans; social security benefits; damage awards and sick pay; Railroad Retirement Board payments includable in income; benefits nontaxable on account of disability.
Patricia Cotroneo (T.C. Memo. 2024-70) Sec. 61; 86; 6015; 6662; 6751; gross income definition; Social Security benefits; innocent spouse relief; accuracy related penalty; procedural requirements; distributions from individual retirement account; IRA; taxabliity of Social Security benefits; IRS showed receipt of income by taxpayer; failure to report partnership income; entitlement to innocent spouse relief; taxpayer knowledge of understatement of tax; IRS failed to show penalty was approved by immediate supervisor.
Arianna H. Mathew (T.C. Memo. 2024-69) Sec. 6330; hearing before levy; collection due proecess; CDP; proposed installment agreement; amended return after start of hearing irrelevant.
Douglas James Casement (T.C. Memo. 2024-68) Sec. 6330; hearing before levy; collection due proecess; CDP; failure to file returns; failure to provide requested financial information; reasonable cause for sustaining levy.
Fabricio Moran (T.C. Memo. 2024-67) Sec. 72; 6651; 6654; distributions from qualified plan; faiure to file or pay; failure to pay estimated tax; tax on early distributions from qualified plan.
Robert W. Smiley, Jr., an Incompetent Person, Margaret T. Smiley, Guardian, et al. (T.C. Memo. 2024-66) Sec. 61; 6651; gross income definition; failure to file or pay; income from qualified plan; taxpayer as trustee of a qualified plan made distributions to self. Ian D. Smith (T.C. Memo. 2024-65) Sec. 7623; expenses of detection of underpayment and fraud; determination of award percentage.
Joseph Spiezio and Louise Spiezio (T.C. Memo. 2024-64) Sec. 172; 6662; net operating losses; accuracy related penalty; proof of loss.
Steven J. Schwartz (T.C. Memo. 2024-63) Sec. 6330; hearing before levy; collection due process; CDP; Collection alternative denied; not in compliance with tax laws.
Alan Hamel and Estate of Suzanne Hamel, Deceased, Alan Hamel, Special Administrator (T.C. Memo. 2024-62) Sec. 6501; limitations on assessment and collection; notice of Final Partnership Administrative Adjustment (FPAA) issued; suspension of partnership item triggered.
Suzanne Jean McCrory (T.C. Memo. 2024-61) Sec. 7623; expenses of detection of underpayment and fraud; determination of award; proceeds in dispute; failure to meet threshold; no authority to order IRS audit.
Excelsior Aggregates, LLC, Big Escambia Ventures, LLC, Tax Matters Partner, et al. (T.C. Memo. 2024-60) Sec. 170, charitable contributions; 13 consolidated cases; fair market value of consdervation easement; valuation method; income capitalization method best method; Court's valuation much less than taxpayer's.
Parkway Gravel, Inc. and Subsidiaries (T.C. Memo. 2024-59) Sec. 6662; accuracy-related penalty; related transactions; arms length dealing at fair market values.Mark G. Strom; Bernee D. Strom (T.C. Memo. 2024-58) Sec. 6015; innocent spouse relief; knowledge of understatement; equitable relief; factors weighed.
Sarah S. O'Nan (T.C. Memo. 2024-57) Sec. 7430; recovery of litigation costs; costs incurred before date of final determinnation letter not recoverable; IRS position substantially justified.
Kiran Rawat, Petitioner, and Raghvendra Singh, Intervenor (T.C. Memo. 2024-56) Sec. 6015; innocent spouse relief; threshold conditions not satisfied.
Gary M. Schwarz and Marlee Schwarz (T.C. Memo. 2024-55) Sec. 183; 6662; not for profit activities; accuracy-related penalty; hobby losses; farming activity; history of losses; probably never become profitable; reliance on competent CPA.
Lisa M. Holley (T.C. Memo. 2024-54) Sec. 6330; hearing before levy; collection due process; CDP; settlement officer followed required procedures in sustaining Notice of Federal Tax Lien; NFTL.
Elizabeth White (T.C. Memo. 2024-53) Sec.6330; hearing before levy; collection due process; CDP; no liability challenge by taxpayer; settlement officer followed procedure.
Buckelew Farm, LLC f.k.a. Big K Farms LLC, Big K LLC, Tax Matters Partner (T.C. Memo. 2024-52) (T.C. Memo. 2024-52) Sec. 170; 6662; charitable contributions; accuracy-related penalty; conservation easement; gift in perpetuity; proportionate share of proceeds on extinguishment; gross valuation misstatement.
Estate of Randy Glassman, Deceased, Steven Glassman, Personal Representative, and Steven Glassman (T.C. Memo. 2024-51) Sec. 6751; procedural requirements; supervisory approval of penalty; challenge to signator due to complexity of audit.
Piccirc, LLC, Pimlico, LLC, A Partner Other Than the Tax Matters Partne (T.C. Memo. 2024-50) Sec. 707; 6662; transactions between partner and partnership; accuracy-related penalty; disguised sales; structured distressed debt investment transaction; multiple partnerships.
Joseph Belcik, et al. (T.C. Memo. 2024-49) Sec. 167 274; 1402; 6651; 6654; 6673; depreciation; business expense substantiation; net earnings from self-employment; failure to file or pay; failure to pay estimated taxes; penalty for delay; recordkeeping; documentation; maintaining frivolous positions; basis in warehouse not established.
Richard A. Shaw, Jr. (T.C. Memo. 2024-48) Sec. 6440; hearing before levy; collection due process; CDP; deadline to file petition; equitable tolling; 30-day filing period.
Michael C. Giambrone; William W. Giambrone and Michele L. Giambrone (T.C. Memo. 2024-47) Sec. 165; 6662; losses; accuracy-related penalty; theft loss; failure to show loss incurred; sale of stock.
John A. Hartmann (T.C. Memo. 2024-46) Sec. 6330; hearing before levy; collection due process; CDP; denial of collection alternatives; requirements met; financially able to make monthly payments; information not provided by taxpayer.
Robert Y. Diaz and Brittany L. Diaz (T.C. Memo. 2024-45) Sec. 911; 7121; foreign earned income exclusion; closing agreements; closing agreement valid; questionable signatures; handwriting experts.
Keith M. Phillip (T.C. Memo. 2024-44) Sec. 6212; notice of deficiency; last known address; failure of IRS to prove proper mailing to taxpayer; jurisdiction of Tax Court.
Christopher S. Pascucci and Silvana B. Pascucci (T.C. Memo. 2024-43) Sec. 165; theft loss; Ponzi scheme; decline in value in variable life insurance policies; assets held in accounts of others.
Estate of Roman J. Finnegan, Deceased, Kevin C. Tankersley, Personal Representative, and Lynnette Finnegan, et al. (T.C. Memo. 2024-42) Sec. 104; damage awards and sick pay; claim that post traumatic stress disorder (PTSD) is a physical injury; no reference in settlement agreement to injury.
Burt Kroner (T.C. Memo. 2024-41) Sec. 6662; 6664; accuracy-related penalty; reasonable cause exception; reliance on professional advice; no evidence regarding nature of advice; lack of information presented to professional; reliance on advice.
Valerie Stephens (T.C. Memo. 2024-40) Sec. 6330; hearing before levy; collection due process; CDP; petition to review determination of collection; 30-day filing period; failure to attach copy of notice of intention to dispute.
Robert A. Zienkowski (T.C. Memo. 2024-39) Sec. 6320; 6440; notice of federal tax lien; hearing before levy; collection due process; CDP; rejection of proposed installment agreement.
Amgen Inc. & Subsidiaries (T.C. Memo. 2024-38) Src 6751; procedural requirements; supervisory approval for penalties; whether supervisor had discretion over penalties; timing of issuance of penalties.
Merrie P. Wycoff (T.C. Memo. 2024-37) Sec. 6330; 6673; hearing before levy; penalty for delay; collection due process; CDP; failure to propose collection alterntives; frivolous filings maintained despite warnings; levy proposed.
Khuram Shahzad Gondal and Arooj Asmat (T.C. Memo. 2024-36) Sec. 61; 6663: gross income definition; civil fraud penalty; unreported income; constructive dividends; business purpose of payments; proof of fraudulent intent.
Savannah Shoals, LLC, Green Creek Resources, LLC, Tax Matters Partner (T.C. Memo. 2024-35) Sec. 170; 6662; charitable contributions; accuracy-related penalty; conservation easement; substantiation requirements; aplprasisal relied on for other information; gross valuation misstatement.
Sunil S. Patel and Laurie McAnally Patel, et al. (T.C. Memo. 2024-34) Sec. 162; 831; business expenses; tax on insurance companies; captive insurance companies; election invalid; payments not insurance premiums.
Rodney A. Taylor (T.C> Memo. 2024-33) Sec. 6330; 6671; 6672; hearing before levy; penalty for delay; failure to collect and pay over taxes; collection due process; CDP; trust fund recovery penalty; responsible person; CEO and sole shareholder; in charge of disbursing funds; funds disbursed to shareholder.
Midwest Medical Aesthetics Center; Kathleen M. Stegman (T.C. Memo. 2024-32) Sec. 61; 162; 6651; 6663; gross income definition; business expenses; failure to file or pay; civil fraud penalty; recordkeeping; substantiation; documentation; cost of goods sold overstated; failure to document certain business expenses; failure to show purchase of assets where depreciation claimed; failure to show business purpose of asset.
George McDonald White (T.C. Memo. 2024-31) Sec. 6330; hearing before levy; collection due process; CDP; failure to file tax returns; collection alternatives denied; not current with estimated taxes; failure to rectify issues; collection action sustained.
Lance C. Standifird (T.C. Memo. 2024-30) Sec. 6651; 6654; failure to file or pay; failure to pay estimated taxes; jurisdiction to determine income tax and self-employment tax deficiencies with respect to partnership level proceeding.
Anthony Aulisio, Jr. (T.C. Memo. 2024-29) Sec. 162; 164; 170, 172, business expenses for taxes, dedution, charitable contributions; net operating loss carryforward; income amounts not corroborated; interest and real estate taxes not substantiated; substantiation of mortgage payments; substantiation of real estate taxes; proof of charitable contributions; failure to prove net operating carryforward loss available.
Ramesh C. Kapur and Chanda Kapur (T.C. Memo. 2024-28) Sec. 41; research tax credits; use of sampling methodology.
Charles Scott and Linder Scott (T.C. Memo. 2024-27) Sec. 104; damage awards and sick pay; Civil Service Retirement System disability payment; amount not attributable to injury or sickness related to time in armed forces.
Zofia Kraszewska, Petitioner, and Simon P. Ricks, Jr., Intervenor (T.C. Memo. 2024-26) Sec. 6015 innocent spouse relief; accuracy related penalty; know or reason to know of understatement; intervenor's concealment of finances from spouse; equitable relief.
Oconee Landing Property, LLC, Oconee Landing Investors, LLC, Tax Matters Partner (T.C. Memo. 2024-25) Sec. 170; charitable contributions; requirements of contribution with return; requirement to attach qualified appraisal; conservation easement; failure to exercise ordinary business care; proof of computation of basis of property.
James Elbert Aldridge, Jr. and Shirley Lorraine Aldridge (T.C. Memo. 2024-24) Sec. 61; 641; 6663; gross income definition; imposition of tax; fraud penalty; six trusts; unreported income; trusts as shams; economic substance; relationship between taxpayer and trust; fraudulent intent.
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 Consolidated 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 levy; 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

James Michael Warren (Summary Opinion 2024-20) Sec. 469; 6662; passive ctivity losses; accuracy-related penalty; real estate professional; documentation as to hours spent in real estate; full-time employee at first job.
Yelena Tolstov (Summary Opinion 2024-19) Sec. 165; 6662; losses; accuracy-related penalty; substantiation of gambling losses.
Jonathan Chang and Wei-Lin Chang (T.C. Summary Opinion 2024-18) Sec. 162; 6662; business expenses; accuracy-related penalty; entity as Sec. 501(c)(3) organization.
Kwaku Eason and Ashley L. Leisner (T.C. Summary Opinion 2024-17) Sec. 162; 6662; business expenses; accuracy-related penalty; engaged in a trade or business; start of business.
Mark F. Coble (T.C. Summary Opinio No. 16) Sec. 6020; 6213 6651; heaing on filing notice of lien; failure to file or pay; Tax Court Petition; substitute for return; SFR; late filed petition; jurisdiction.
Jeffrey R. Pope and Davin L. Pope (T.C. Summary Opinion No. 15) Sec. 219; Individual Retirement Account; IRA; contributions; errors in completing return.
Abhishek Bachchan and Gitika Gupta (T.C. Summary Opinion No. 14) Sec. 274; 280A; 6651; 6662; business expense substantiation; home office; failure to file or pay; accuracy-related penalty; unreimbursed employee business expenses; documentation; recordkeeping.
Timothy L. Foradis and Jessica L. Moore (T.C. Summary Opinion No. 13) Sec. 169; passive activity losses; rental losses; participation as real estate professional; hours worked; hours spent not credible.
Gregory Alexander Morino (T.C. Summary Opinion 2024-12) Sec. 61; 6662; 6651; 6673; gross income definition; accuracy-related penalty; failure to file or pay; penalty for delay; unreported income; substantiation; documentation; recordkeeping; claimed deductions disallowed; car and truck expenses; frivolous arguments.
Jon K. Palsgaard and Kimperly A. Kelly (T.C. Summary Opinion 2024-11) Sec. 86; Social Security benefits; Social Security Disability benefits (SSD) taxable as Social Security; amount reported on SSA-1099. Edward George Shlikas (T.C. Summary Opinion 2024-10) Sec.72; 6662; early distributions; accuracy related penalty; penalty tax on premature distributions; first time homebuyer exception for early distribution only available to distributions from IRA.
Carol A. Wright, et al. (T.C. Summary Opinion 2024-9) Sec. 162; 274; business expenses; business expense substantiation; ordinary and necessary business expenses; documentation; recordkeeping; proof of expenses; documentation presented to the Court; organization of documentation.
Oleg Kolomiyets (T.C. Summary Opinion 2024-8) Sec. 162; 274; 280F; 6662; business expenses; business expense substantiation; luxury autos; accuracy related penalty; recordkeeping; documentation; separate books and records; listed property; car log.
Jose Banuelos and Carol Ann Banuelos (T.C. Summary Opinion 2024-7) Sec. 62; 162; 6662; adjusted gross income defined; business expenses; accuracy-related penalty; fee basis employee; fees collected from public; unreimbursed business expenses.
Brett Stevan Jurries and Sherise Julie Bruce (T.C. Summary Opinion 2024-6) Sec. 6015; 6662; innocent spouse relief; accuracy-related penalty; proportionate relief; equitable relief.
Justin M. Maderia (T.C. Summary Opinion 2024-5) Sec. 6662; accuracy-related penalty; failure to report dividends; constructive dividends from closely held corporation; personal expenses paid by corporation or unsubstantiated expenditures.
Caren Kohl, a.k.a. Caren Rein (T.C. Summary Opinion 2024-4) Sec. 72; 6651; distributions from qualified plans; failure to file or pay; early distributions; distribution not reported.
Paul Anthony Steward (T.C. Summary Opinion 2024-3) Sec. 162; 274; 6651; 6662; business expenses; business expense substantiation; failure to file or pay; accuracy related penalty; records destroyed in fire; reconstruction; ordinary and necessary.
Patricia S. Chappell (T.C. Summary Opinion 2024-2) Sec. 162; 274; 6662; business exenses; business expense substantiation; accuracy-related penalty; recordkeeping; documentation; Cohan rule; automobile use; standard mileage rate.
Scott Paulson and Melissa Lowery Paulson (T.C. Summary Opinion 2024-1) Sec. 162; 6662; business expenses; accuracy-related penalty; documentation; recordkeeping; substantiation; summary judgment.

--Last Update 10/05/24