Below is a list of the 2025 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--2024
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

Silver Moss Properties, LLC, Silas Mine Investments, LLC, Tax Matters Partner (165 T.C. No. 4) Sec. 6663; civil fraud penalty; entitlement to jury trial; provisions of TEFRA.

Memorandum Decisions

John J. Mongogna and Michelle L. Mongongna (T.C. Memo. 2025-89) Sec. 6330; hearing before levy; collection due process; CDP; failure to provide financial information; no written proposal for installment agreement; access to equity in real estate.
Corri A. Feige (T.C. Memo. 2025-88) Sec. 83; 6651; property transferred in connection with performance of services; failure to file or pay; gift of shares of employer as income; substantial risk of forfeiture; no restrictions on transfer.
Dax Xavier Johnson (T.C. Memo. 2025-87) Sec. 170; 6651; charitable contributions; failure to file or pay; substantiation requirements for charitable contribution; authenticity of acknowledge letter; proper mailing of deficiency notice.

Summary Opinions

None

Tax Court Cases

Silver Moss Properties, LLC, Silas Mine Investments, LLC, Tax Matters Partner (165 T.C. No. 4) Sec. 6663; civil fraud penalty; entitlement to jury trial; provisions of TEFRA.
Moxon Corp0oration (165 T.C. No. 2) Sec. 6662; 6664; accuracy-related penalty; definitions and special rules for penalties; deficiency procedures under Sec. 6320; last known address.
JM Assets, LP, A-A-A Storage, LLC, Partnership Representative (165 T.C. No. 1) Sec. 6235; period of limitations on assessments; regulation invalid; adequate disclosure of omitted income; Notice of Final Partnership Adjustment untimely.

Abbvie Inc. and Subsidiaries (164 T.C. No. 10) Sec. 1234A; gains or losses from certain terminations; "break free agreement"; ordinary vs. capital loss; capital gain or loss must be related to a capital asset.
Facebook, Inc. & Subsidiaries (164 T.C. No. 9) Sec. 482; allocation of income and deductions among taxpayers; valuation of platform contributions; arm's length result; income method model.
Alberto Garcia, Jr. (164 T.C. No. 8) Sec. 7345; revocation or denial of passport in certain tax delinquencies; seriously delinquent tax debt; legally enforceable debt; expiration of limitations period.
Belagio Fine Jewelry, Inc. (164 T.C. No. 7) Sec. 7463; 7502; determination of employment status; timely mailing as timely filing; 90-day deadline; non-jurisdictional; private courier service.
Ranch Springs, LLC, Ranch Springs Investors, LLC, Tax Matters Partner (164 TC No. 6) Sec. 170; 6662; charitable contributions; accuracy-related penalty; gross valuation misstatement; purchase price of arm's length transaction best indication of contributed value.
CF Headquarters Corporation (164 TC No. 5) Sec. 102; 118; 139; gifts and inheritances; contributions to capital; qualified disaster relief payment; federa; grant not excludable from income under taxpayer theories.
Eaton Corporation and Subsidiaries (164 T.C. No 4) Sec. 960; deemed paid credit for foreign tax credit; no dividend distribution; inclusions not taken into account.
Robert Donlan, Jr. and Kegan Donlan (164 T.C. No. 3) Sec. 6061; 7453; signing of returns and other documents; Tax Court rules of practice and procedure; electronically signed petition valid.
Charlton C. Tooke III (164 T.C. No. 2) Sec. 7803; Commissioner of Internal Revenue; appointment of Officers of the United States; Appeals Officers; definitions; responsibilities and authority.
Capitol Places II Owner, LLC, Historic Preservation Fund 2014 LLC, A Partner Other Than The Tax Matters Partner (164 T.C. No. 1) Sec. 170; charitable contributions; facade easement; failure to have building certified as a historic structure.

Memorandum Decisions

John J. Mongogna and Michelle L. Mongongna (T.C. Memo. 2025-89) Sec. 6330; hearing before levy; collection due process; CDP; failure to provide financial information; no written proposal for installment agreement; access to equity in real estate.
Corri A. Feige (T.C. Memo. 2025-88) Sec. 83; 6651; property transferred in connection with performance of services; failure to file or pay; gift of shares of employer as income; substantial risk of forfeiture; no restrictions on transfer.
Dax Xavier Johnson (T.C. Memo. 2025-87) Sec. 170; 6651; charitable contributions; failure to file or pay; substantiation requirements for charitable contribution; authenticity of acknowledge letter; proper mailing of deficiency notice.
Whistleblower 20442-18W (T.C. Memo. 2025-86) Sec. 7623; expenses of detection of underpayment and fraud; information provided obtained from public sources; IRS already investigating target; information did not substantially contribute; supplemental submissions and extension of claim period.
Christopher B. Epps (T.C. Memo. 2025-85) Sec. 6330; hearing before levy; collection due process; CDP; failure to submit installment agreement or offer-in-compromise; review of financial statuso hardship determined.
Tisha S. Hillman (T.C. Memo. 2025-84) Sec. 6330; hearing before levy; collection due process; CDP; failure to accept installment agreement; failure to file amended return; Appeals Officer considered financial situation.
CFM Insurance, Inc. v. Commissioner; Robertino Presta and Antonella Presta (T.C. Memo. 2025-83) Sec. 831; 6662; tax on insurance companies; accuracy-related penalty; microcaptive insurance company; definition of insurance; distribution of risks; insurance practices.
Sohail S. Hussaini (T.C. Memo. 2025-82) Sec. 62; 67; adjusted gross income defined; 2% floor on miscellaneous itemized deductions; wages reported on W-2; deduction for travel expenses deducted on Schedule 1 category for reservists, performing artists etc.; law allows no deduction under TCJA.
Curtis K. Kadau and Lori A. Kadau, Deceased, Curtis K. kadau, Personal Representative (T.C. Memo. 2025-81) Sec. 162; 6662; business expenses; accuracy-related penalty; captive insurance company; transaction not qualified as insurance; premiums not deductible; arm's-length transaction.
Adrienne Mennemeyer (T.C. Memo. 2025-80) Sec. 61; 104; 6651; gross income definition; damage awards and sick pay; failure to file or pay; awards from employer were for employment-related claims including defamation not physical injuries; language in settlement agreement.
River Moss Property, LLC, River Moss Management, LLC, partnership Representative (T.C. Memo. 2025-79) Sec. 6662; 6751; accuracy-related penalty; procedural requirements; supervisory approval of penalty; conservation easement; FPA; final partnership adjustment.
Genie R. Jones, et al. (T.C. Memo. 2025-78) Sec. 162; 831; 832; business expenses; tax on insurance companies; insurance company taxable income; microcaptive insurance companies; amounts paid income as insurance premiums; did not constitute insurance.
Abdul Khaliq Mustafa Muhammad (T.C. Memo. 2025-77) Sec. 6663; 6751; civil fraud penalty; procedural requirements; supervisory approval; unreported income; deductions disallowed for lack of substantiation; failure to maintain records; badges of fraud.
Estate of Billy S. Rowland, Deceased, James A. Park, Executor (T.C. Memo. 2025-76) Sec. 2010; unified credit against estate tax; spousal unused exclusion amount; DSUE; election timeliness; return filed late; lack of information on fair market value of assets.
Jefferson Property Holdings, LLC, Strategic Fund Manager, LLC, Partnership Representative (T.C. Memo. 2025-75) Sec. 6662; 6751; accuracy-related penalty; procedural requirements; supervisory approval; gross valuation misstatement.
Sand Valley Holdings, LLC, Sand Valley Investors, LLC, Tax Matters Partner (T.C. Memo. 2025-74) Sec. 6662; 6741; accuracy-related penalty; procedural requirements; supervisory approval.
Rock Cliff Reserve, LLC, Five Rivers Conservation Group, LLC. Tax Matters Partner, et al. (T.C. Memo. 2025-73) Sec. 170; 6662; charitable contributions; accuracy-related penalty; appraisals not qualified appraisals; managing partner knew of overvaluation; deduction disallowed in full.
Donna Davis (T.C. Memo. 2025-72) Sec. 6213; petition to Tax Court; late filed; last known address; change of address not on file.
Arden Row Assets, LLC, Natural Aggregates Partners, LLC, Partnership Representative (T.C. Memo. 2025-71) Sec. 170; charitable contributions; conservation easement; document requirement not met; error by taxpayer in litigating.
Remus Beleiu and Naomi J. Beleiu (T.C. Memo. 2025-70) Sec. 6663; fraud penalty; unreported income; failure to maintain records; badges of fraud examined; undisclosed business.
Chad T. Mackland and Tina M. Mackland (T.C. Memo. 2025-69) Sec. 6320; 6330; hearing on filing notice of lien; hearing before levy; collection due process; CDP; dispute of notice of deficiency untimely; underlying liability; installment agreement denied.
Anaheim Arena Management, LLC, H&S Investments I, LP, A Partner other than the Tax Matters Partner (T.C. Memo. 2025-68) Sec. 166; losses; bad debts; advances were not bona fide debt; debt-equity factors examined; economic substance; capital contribution; (subsequently corrected).
Paul H. Christiansen (T.C. Memo. 2025-67) Sec. 6662; 6673; accuracy-related penalty; penalty for delay; substantial understatement; frivolous arguments; failure to report income.
Bobby G. Glasser and Cathleen A. Glasser (T.C. Memo. 2025-66) Sec. 6323; 6330; validity and priority of liens; hearing before levy; collecion due process; CDP; Notice of Federal Tax Lien sustained while installment agreement active; failure to meet conditions for lien withdrawal; procedural requirements satisfied.
Luis Carlos Ibarra Cano (T.C. Memo. 2025-65) Sec. 6212; Notice of Deficiency; IRS failure to send to last known address; notice of deficiency not valid.
Steven J. Schwartz (T.C. Memo. 2025-64) Sec. 6330; hearing before levy; collection due process; CDP; installment agreement denied; noncompliance with estimated tax requirements; failure to adequately disclose financial situation.
Ivey Branch Holdings, LLC, Ivey Branch Investors, LLC, Tax Matters Partner (T.C. Memo. 2025-63) Sec. 6751; procedural requirements; supervisory approval of penalty; donation of conservation easement; who is proper supervisor.
Lisa Cristoph Towarnicky (T.C. Memo. 2025-62) Sec. 6512; 7430; limitations on petition to Tax Court; recovery of litigation costs; IRS compliance with refund determination and application of refund; lack of evidence of litigation costs.
Inga I. Kramarenko (T.C. Memo. 2025-61) Sec. 61; 6662; gross income definition; accuracy-related penalty; postdoctoral researcher compensation; not exempt under treaty; factors influencing decision.
Albert Mark Fonda (T.C. Memo. 2025-60) Sec. 61; 6673; gross income definition; penalty for delay; wages are taxable income; distributions from retirement plan; frivolous arguments.
Christopher L. Huber and Ashley M. Huber (T.C. Memo. 2025-59) Sec. 61; gross income definition; wages as taxable income; W-2 and biweekly earnings statements.
Kent Trembly (T.C. Memo. 2025-58) Sec. 6330; hearing before levy; collection due process; CDP; compliance with requirements concerning validity of assessments; failure to participate in hearing.
Michael Austin French and Dawn Michelle French (T.C. Memo. 2025-57) Sec. 61; 6673; gross income definition; penalty for delay; frivolous arguments; taxability of wages.
Joanne A. Horsham (T.C. Memo. 2025-56) Sec. 6323; 6330; validity and priority of lien; hearing before levy; collection due process; CDP; direct debit installment agreement; lien withdrawal discretionary in installment agreement.
Hani G. Ataya (T.C. Memo. 2025-55) Sec. 6662; accuracy-related penalty; underpayment resulting from dividends and disallowed Schedule C deductions.
Daniel Palli (T.C. Memo. 2025-54) Sec. 6320; 6330; 6502; hearing on filing notice of lien; hearing before levy; collection after assessment; collection due process; CDP; delay in considering an offer-in-compromise; OIC; failure to provide financial information.
Beaverdam Creek Holdings, LLC, Beaverdam Creekinvestors, LLC, Tax Matters Partner (T.C. Memo. 2025-53); Sec. 170; 6662; charitable contributions; accuracy-related penalty; gross overstatement of fair market value of contribution; income projections from quarry speculative; sales comparison method more reliable.
Soroban Capital Partners LP, Soroban Capital Partners GP LLC, Tax Matters Partner (T.C. Memo. 2025-52) Sec. 1401; 1402; rate of tax on self-employment income; self-employment tax definition; distributive shares subject to net earnings from self-employment; material participation; control over operations; limited partners; income from services not capital; TEFRA partnership.
James M. Root and Valerie K. Root (T.C. Memo. 2025-51) Sec. 165; 172; 6662; 6751; losses; net operating losses; accuracy-related penalty; procedural requirements; NOL; losses in a trade or business; existence of business; structural problems with building not deductible; definition of trade or business; supervisory approval of penalty; proof of NOL.
Hancock County Land Acquisitions, LLC, Southeastern Argive Investments, LLC, Tax Matters Partner (T.C. Memo. 2025-50) Sec. 6751; procedural requirements; supervisory approval of penalty.
Jordan John O'Neill (T.C. Memo. 2025-49) Sec. 6213; 7502; Petition to Tax Court restrictions; timely mailing, timely filing; proper mailing; issuance by official without authority; late-filed petition; evidence of mailing by IRS; notices unclaimed.
John Joseph Bauche (T.C. Memo. 2025-48) Sec. 7122; compromises; deemed acceptance of compromise; written rejection by the IRS; inadequate consideration of offer-in-compromise; remand to IRS Office of Appeals,
Estate of Martin W. Griffin, Deceased, Christopher Griffin, Executor (T.C. Memo. 2025-47) Sec. 2056; bequests to surviving spouse; marital deduction; Qualified terminable interest property QTIP; state law.
Virgil Joseph Aiello (T.C. Memo. 2025-46) Sec. 6330; hearing before levy; collection due process; CDP; petition to challenge notice of determination filed untimely; equitable tolling; sent to IRS not Tax Court.
Kirk Stevens and Shannon Stevens (T.C. Memo. 2025-45) Sec. 163; 6662; interest deductions; accuracy-related penalty; promissory note not bona fide debt; lacked econcomic substance; liability to repay; note and option agreement.
Herbert J. Stokey (T.C. Memo. 2025-44) Sec. 6213; Tax Court petitions; petition to Tax Court for redetermination: last known address from most recent return.
Norwich Commercial Group, Inc. (T.C. Memo. 2025-43) Sec. 1341; claim of right; deduction for income overreported in prior years; no unrestricted right to funds.
Peter Joseph Isaiah Gibbons O'Connor (T.C. Memo. 2025-42) Sec. 6651; 6654; 6673; failure to file or pay; failure to pay estimated tax; penalty for delay; frivolous arguments; repeated failure to file.
Thomas S. Miller (T.C. Memo. 2025-41) Sec. 6651; failure to file or pay; civil fraud; collateral estoppel; fraud established as a result of prior conviction for criminal fraud.
Shirley Coleman Burl (T.C. Memo. 2025-40) Sec. 6330; hearing before levy; collection due process; CDP; allowable expenses exceeding income based on financial statements; currently not collectible status (CNC); no legal error on which to challenge hearing; petition dismissed.
Chimney Rock Holdings, LLC, Ornstein-Schuler, LLC, Tax Matters Partner (T.C. Memo. 2025-39) Sec. 6226; alternative to payment of imputed underpayment by partnership; indirect partners in a limited liability company denied participation in case; conservation easement donation; failure to file motion.
Dealers Auto Auction of Southwest LLC (T.C. Memo. 2025-38) Sec. 6050I; 6721; 6722; 6724; failure to file correct information returns; failure to furnish correct information returns; waiver, definitions and special rules; returns relating to cash received in trade or business; cash receipts of more than $10,000; reliance on software; failure to show taxpayer acted reasonably.
Joanne Salvi Vanover, PLetitioner, and Michael D. Vanover, Intervenor (T.C. Memo. 2025-37) Sec. 6015; innocent spouse relief; equitable relief; reason to know of unreported income; lack of actual knowledge of deficiency; partial relief granted.
Clark J. Gebman and Rebecca Gebman (T.C. Memo. 2025-36) Sec. 6232; 6330; validity and priority against certain persons; hearing before levy; notice of federal tax lien; requirements met; failure to provide grounds for withdrawal of lien; collection due process; CDP.
Mark P. Himmel and Deborah W. Himmel (T.C. Memo. 2025-35) Sec. 183; 6651; not-for-profit activities; failure to file or pay; hobby losses; horse breeding and boarding; failure to generate a profit; nine-factor test applied factors weighed.
GWA, LLC, George A. Weiss, Tax Matters Partner (T.C. Memo. 2025-34) Sec. 475; 481; 6662; mark to market accounting method for securities dealers; changes in method of accounting; accuracy-related penalty; transactions not options; lacked characteristics of options.
Joseph J. Zajac, III (T.C. Memo. 2025-33) Sec. 61; 104; 162; 170; 6662; gross income definition; damage awards and sick pay; business expenses; charitable contributions; accuracy-related penalty; portion of award excludable for physical injury and related emotional distress; business expenses not shown to be ordinary and necessary; lack of documentation for charitable contributions and miscellaneous itemized deductions.
Douglas E. Hampton (T.C. Memo. 2025-32) Sec. 165; losses; seizure of funds by U.S. Marshals Service; related to guilty plead to bribery and other charges; individual and S corporation involved; no loss deduction allowed; no passthrough loss allowed.
Melissa Correll (T.C. Memo. 2025-31) Sec. 152; child tax credit; qualification; dependent; noncustodial parent; live in abode more than one-half of year.
WT Art Partnership LP, Lonicera LLC, Tax Matters Partner (T.C. Memo. 2025-30) Sec. 170; 6662; charitable contributions; accuracy-related penalty; qualified appraisal requirement; qualified appraiser; reasonable cause; reliance on professionals; consistency of procedures over several years; prior IRS audits; gross valuation misstatement.
Kaleb J. Pierce (T.C. Memo. 2025-29) Sec. 2512; valuation of gifts; discounts for lack of control and marketability; 5-percent for lack of control; 25-percent for lack of marketability; cash flow method for valuation; determination of cost of capital; company specific risk factor.
Kelly M. Strieby and Jan E. Sharon-Strieby (T.C. Memo 2025-28) Sec. 48; 469; 6662; energy credit; passive activity losses and credits; accuracy-related penalty; material participation in activity; energy credit subject to passive activity rules.
David Nwafor (T.C. Memo. 2025-27) Sec. 174; 6662; amortization of research and experimentation expenditures; accuracy-related penalty; value of imputed labor; self-performed labor; deductions denied for lack of records; documentation; no deduction for discounts given to customers.
Gina Jaha; Bob Anderson (T.C. Memo. 2025-26) Sec. 274; 6651; 6654; business expense substantiation; failure to file or pay; failure to pay estimated tax; assignment of income; recordkeeping; documentation; proof of expenditures; insufficient information to apply Cohan rule
Genie R. Jones et al. (T.C. Memo. 2025-25) Sec. 162; 831; business expenses; tax on insurance companies; micro-captive insurance arrangement; related insurer; definition of insurance, insurance company.
Sherman Derell Smith (T.C. Memo. 2025-24) Sec. 167; depreciation; fair market value or adjusted basis; conversion of property from personal to rental use; proof of original cost and improvements.
Charlie Campana (T.C. Memo. 2025-23) Sec. 61; 72; 6662; gross income definition; distributions from qualified plans; accuracy-related penalty; early withdarwal penalty from qualified plan.
Drew J. Pfirrman (T.C. Memo. 2025-22) Sec. 6330; 6331; 7345; hearing before levy; levy and distraint; revocation of passport in seriously delinquent tax debt; challenges to underlying liability not allowed in passport cases; full satisfication of debt required.
Paul H. Christiansen and Terre Lynn Charistiansen (T.C. Memo. 2025-21) Sec. 61; 85; 6651; gross income definition; unemployment compensation; failure to file or pay; inclusion in gross income; frivolous arguments.
William J. Cade and Mary E. Cade (T.C. Memo. 2025-20) Sec. 170; charitable contributions; appraisal requirements; qualified appraiser.
Alan Hamel and Estate of Suzanne Hamel, Deceased, Alan Hamel, Special Administrator (T.C. Memo. 2025-19) Sec. 6229; status of unidentified partner; required information not provided to IRS as required; assessment period extended.
Scott A. Blum and Audrey R. Blum (T.C. Memo. 2025-18) Sec. 6651; 6662; failure to file or pay; accuracy-related penalty; gross valuation misstatement; tax shelter transaction loss; economic substance.
Richard L. Brown and Camille C. Brown (T.C. Memo. 2025-17) Sec. 6330; hearing before levy; collection due process; CDP; offer-in-compromise; consideration of economic hardship; special circumstances not hardship.
Heather Weston; Stewart Weston (T.C. Memo. 2025-16) Sec. 162; 165; 6651; 6654; business expenses; losses; failure to file or pay; failure to pay estimated taxes; theft loss claim; business loss; lack of substantiation; documentation; recordkeeping; trade or business or investor; not trade or business loss not dedcuctible; reasonable prospect of recovery.
Green Valley Investors, LLC, et al., Bobby A. Branch, Tax Matters Partner (T.C. Memo. 2025-15) Sec. 170; 6662; 6751; charitable contributions; accuracy-related penalty; procedural requirements; supervisory approval of penalty; conservation easement; perpetuity requirement; highest and best use; mining site not financially feasible; substantial gross valuation misstatement.
Peoplease LLC (T.C. Memo. 2025-14) Sec. 6330; hearing before levy; collection due process; CDP; Employee Retention Tax Credit as satisfaction of unpaid payroll tax liabilities; EITC; submission of Form 941-X; issues not raised during CDP hearing not in jurisdiction of Tax Court.
James Clark (T.C. Memo. 2025-13) Sec. 1401; 6662; self-employment tax; accuracy-related penalty; freelance writer; other income vs. self-employment income; reasonable cause to avoid penalty not shown.
Thomas W. Langlois (T.C. Memo. 2025-12) Sec. 162; 704; 6662; business expenses; partner's distributive share; accuracy-related penalty; unreimbursed business expenses not substantiated; basis not shown with which to claim losses; failure to show business purpose of expenses.
Park Lake II, LLC, Park Lake Partners, LLC, Tax Matters Partner (T.C. Memo. 2025-11) Sec. 6662; 6662A; 6751; accuracy-related penalty; imposition of accuracy-related penalty with respect to reportable transactions; procedural requirements; supervisory approval of penalty; gross valuation misstatement penalty; donation of conservation easement.
Carol Mahr Besore (T.C. Memo. 2025-10) Sec. 6330; hearing before levy; collection due process; CDP; settlement officer verified requirements of applicable law, considered issues raised by taxpayer, balanced collection action and intrusion.
Karl W. Leo and Fay L. Leo (T.C. Memo. 2025-9) Sec. 170; 6662; charitable contributions; accuracy-related penalty; gross valuation misstatement penalty; Tax Court determination lower than IRS valuation; income approach was not the best method; property partly rented other part unrentable without major repairs.
Ana M. Franklin (T.C. Memo. 2025-8) Sec. 61; 162; 172; 6651; gross income definition; business expenses; net operating losses; failure to file or pay; NOL; loan vs. embezzlement; repayment of appropriated funds from local government; repayment did not constitute loss for NOL; not a trade or business.
Sonji Marie Mosley (T.C. Memo. 2025-7) Sec. 72; 172; 6651; 6654; distributions from qualified plans; net operating losses; failure to file or pay; estimated tax penalty; NOL; substantiation of net operating loss; failure to make election to relinquish carryback; capital loss.
Seabrook Property, LLC, Seabrook Manager, LLC, Tax Matters Partner (T.C. Memo. 2025-6) Sec. 170; 6662; charitable contributions; accuracy-related penalty; conservation easement; donative intent; gross valuation misstatement; generally accepted appraisal standards.
Cassandra Allen (T.C. Memo. 2025-5) Sec. 6212; notice of deficiency; unreported income from information returns; no dispute as to any material fact.
Debra Reed and Timothy Read (T.C. Memo. 2025-4) Sec. 6330; hearing before levy; collection due process; CDP; petition to review levy; 30-day period; failure to state a claim.
Yosef Sehati a.k.a. Joseph Sehati and Lilly Kohanim-Sehati, et al (T.C. Memo. 2025-3) Sec. 482; 1366; 6662; 6663; allocation of income and deduction among taxpayers; pass-through of items to S shareholders; accuracy-related penalty; civil fraud penalty; cash hoard.
Ishveen K. Khopra (T.C. Memo. 2025-2) Sec. 162; 6663; business expenses; civil fraud penalty; unsupported deductions; altered documents; badges of fraud; no gross income from consulting activity.
Matthew D. Hutcheson and Annette Hutcheson (T.C. Memo. 2025-1) Sec. 61; 72; 6651; 6663; gross income definition; distributions from qualified plans; failure to file or pay; distributions as taxable income; penalty for early IRA withdrawal; badges of fraud.

Summary Opinions

John Henry Besaw (T.C. Summary Opinion 2025-7) Sec. 170; 1016; charitable contributions; adjustments to basis; propoerty contributions to charity; Form 8283; complete information.
Manuela C. Smith (T.C. Summary Opinion 2025-6) Sec. 6015; innocent spouse relief; threshold requirements met; intervenor opposing relief; knowledge of income.
Safdar S. Khan and Maryam Tahir (T.C. Summary Opinion 2025-5) Sec. 274; 6001; business expense substantiation; requirement to keep records, statements and special returns; documentation; recordkeeping; Cohan rule.
Linsey Goodale (T.C. Summary Opinion 2025-4) Sec. 6330; hearing before levy; collection due process; CDP; requested documents not provided; failure to attend CDP hearing.
Amanda Renee Stewart, Petitioner; And Ahmed Zied, Intervenor (T.C. Summary Opinion 2025-3) Sec. 6015; 6662; innocent spouse relief; accuracy-related penalty; knowledge of income; relief from joint and several liability. Michael D. Taylor (T.C. Summary Opinion 2025-2) Sec. 165; 6662; losses; accuracy-related penalty; casualty loss for real property damaged in hurricane disallowed; property not owed by taxpayer; property in trust for taxpayer's children.
Roger M. Fredenberg and Kimberly D. Fredenberg (T.C. Summary Opinion 2025-1) Sec. 183; 274; 6662; not-for-profit activities; business expense substantiation; accuracy-related penalty; rental property; appreciation in value factored into profit motive; auto deductions; car logs; unreimbursed business explenseas.

--Last Update 08/23/25