Jason Freeman on IRS

Tax Court in Brief | Pressman v. Comm’r | Deductibility of Home Mortgage Interest and Penalties

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Domdom v. Comm’r, T.C. Summary Opinion...more

9/22/2022 / Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Mortgage Interest , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Domdom v. Comm’r | Foreign Earned Income and Tax Home for U.S. Income Tax

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more

9/21/2022 / Foreign Earned Income , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Sparta Pink Property, LLC v. Comm’r | Conservation Easement and Additional Fodder for Circuit Split

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Domdom v. Comm’r, T.C. Summary Opinion 2022-17 | August 30, 2022 | Carluzzo, J. | Dkt. No. 18270-17S Pressman v. Comm’r, T.C. Summ. Op. 2022-15 |...more

9/20/2022 / Charitable Deductions , Conservation Easements , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning

The IRS Appeals Office

The IRS Independent Office of Appeals (“IRS Appeals”) was established to provide an “independent” IRS function that is separate and independent from the IRS’s compliance functions that maintain responsibility for collecting...more

9/20/2022 / Appeals , Collection Action , Ex-Parte Communications , Income Taxes , IRS , Tax Liability , Tax Planning

Is a Stiftung a Foreign Trust? Form 3520 Penalties?

In the recent case of Rost v. United States, the Fifth Circuit analyzed whether a foreign entity should be classified as a foreign trust subject to IRS Form 3520 penalties. The case arose in the context of a Liechtenstein...more

9/19/2022 / Federal Taxes , Filing Requirements , Foreign Trusts , Income Taxes , IRS , Required Forms , Tax Liability , Tax Planning , Tax Returns

Buff was Kind of Weak: FBAR Penalties

A recent FBAR case—well, kind of—serves as a reminder that FBAR penalties can be [*fill in your pejorative adjective of choice*]. In United States v. Buff, the government initiated a suit to collect unpaid civil penalties...more

9/19/2022 / Bank Secrecy Act , FBAR , Foreign Bank Accounts , IRS , Motion for Reconsideration , Offshore Funds , Willful Violations

Tax Court in Brief | Deitch v. Comm’r; and Barry v. Comm’r | Deductible Interest Under IRC 163

Tax Litigation: The Week of August 22nd, 2022, through August 26th, 2022 Warner Enterprises, Inc. v. Comm’r, T.C. Memo. 2022-85 | August 22, 2022 | Buch, J. | Dkt. No. 17163-19L. ...more

9/13/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Partnerships , Tax Court , Tax Deductions , Tax Liability , Tax Planning , TEFRA

Tax Court in Brief | Warner Enters., Inc. v. Comm’r | TEFRA and Partner’s Belated Objection to Penalty Determination

Tax Litigation: The Week of August 22nd, 2022, through August 26th, 2022 Alexander C. Deitch v. Comm’r, No. 21282-17; and Jonathan D. Barry and Susan S. Barry v. Comm’r, No. 21283-17, T.C. Memo 2022-86 | August 25, 2022 |...more

9/12/2022 / Income Taxes , IRS , Partnerships , Tax Court , Tax Liability , Tax Planning , TEFRA

Tax Court in Brief | Medtronic, Inc. v. Comm’r | Section 482, Comparable Uncontrolled Transaction, Comparable Profits Method

Tax Litigation: The Week of August 15th, 2022, through August 19th, 2022 Medtronic, Inc. v. Comm’r, T.C. Memo. 2022-84 | August 18, 2022 | Kerrigan, J. | Dkt. No. 6944-11. Short Summary: This opinion regards a transfer...more

8/22/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Section 482 , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Treasury Regulations

Tax Court in Brief | Whistleblower 769-16W v. Comm’r | Can the Tax Court divest itself of jurisdiction over a whistleblower...

Tax Litigation: The Week of August 1st, 2022, through August 5th, 2022 Eze v. Comm’r, T.C. Memo. 2022-83 | August 4, 2022 | Lauber, J. | Dkt. No. 21425-19...more

8/11/2022 / Internal Revenue Code (IRC) , IRS , Jurisdiction , Motion to Remand , Tax Court , Whistleblower Protection Policies , Whistleblowers

Tax Court in Brief | Hall v. Commissioner | Additions to Tax for Underpayments and Income from Trusts

8/5/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Elstein v. Commissioner | Reasonable Cause Defense for Failure to File

8/5/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Kinney v. Commissioner | Schedule C Deductions Legal Fees, Insurance, Car and Travel Expenses

Tax Litigation: The Week of July 25th, 2022, through July 29th, 2022 Elstein v. Comm’r, T.C. Summary Opinion 2022-14 | July 18, 2022 | Panuthos, J. | Dkt. No. 18272-17S Hall v Commissioner, T.C. Memo. 2022-82 | July 28, 2022...more

8/3/2022 / Business Expenses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Thompson v. Commissioner | Conservation Easements: Donor Improvement Carve-Outs and Supervisory Approval for...

8/3/2022 / Conservation Easements , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Rojas v. Commissioner | Deduction of Alimony and Child Support Under IRC Section 215

8/2/2022 / Alimony , Child Support , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Cuts and Jobs Act , Tax Liability , Tax Planning

Tax Court in Brief | Soler v. Commissioner | Innocent Spouse Relief Under 6015(b) and (f) Denied

7/29/2022 / Income Taxes , IRS , Joint and Several Liability , Joint Tax Returns , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Gonzalez v. Commissioner | Proving Up Business Expenses

7/29/2022 / Business Expenses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Pettennude v. Commissioner | A Warning to All Tax Matters Partners Under TEFRA

7/29/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , TEFRA

Tax Court in Brief | Larochelle v. Commissioner | Unreported IRA Distribution and Reliance on Professional

7/25/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Kelly v. Commissioner | First-Time Abatement, Failure to File, and Failed Leniency

7/21/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Liens , Tax Planning , Tax Returns

Tax Court in Brief | Knight v. Commissioner | Collection Due Process and No Abuse of Discretion

Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Colbert v Commissioner, T.C. Memo. 2022-74 | July 13, 2022 |Wells, J.| Dkt. No. 8395-16. Kelly v. Comm’r, No. 13353-21L, T.C. Memo 2022-73 | July 13, 2022...more

7/21/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Colbert v. Commissioner | Accuracy-Related Penalties and IRS Procedural Requirements

7/20/2022 / Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Estate of DeMuth v. Commissioner | Are Uncashed Gift Checks Includable in an Estate for Federal Income Tax...

7/19/2022 / Deficiency Notices , Gifts , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Planning

Tax Court in Brief | Whistleblower 972-17W v. Commissioner | Whistleblower Entitled to Unredacted (Mainly) Administrative Record

7/19/2022 / Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns , Whistleblower Protection Policies , Whistleblowers

Tax Court in Brief | Wolpert v. Commissioner | Schedule C Itemized Business Expense Deductions and Substantiation

Tax Litigation: The Week of July 4th, 2022, through July 8th, 2022 Barrington v. Commissioner, T.C. Memo. 2022-68 | July 6, 2022 | Buch, J.| Dkt. No. 1781-14 Couturier v. Commissioner, No. 19714-16, T.C. Memo 2022-69 | July...more

7/18/2022 / Business Expenses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Jason Freeman

Freeman Law

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