Jason Freeman

Jason Freeman

Freeman Law

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Tax Court in Brief | Jackson v. Commissioner | What’s at Issue in Reviewing the Determination of a Collection Due Process Hearing?

Tax Litigation:  The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Rogerson v. Commissioner, TC Memo. 2022-49| May 12, 2022 | Toro, J. |...more

5/26/2022  /  Due Process , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Rogerson v. Commissioner | Passive Income, Rent of Yachts, and Reliance on Competent Tax Counsel

Tax Litigation: The Week of May 9th, 2022, through May 13th, 2022 Lewis v. Commissioner, TC Memo. 2022-47| May 9, 2022 | Greaves, J. | Dkt. No. 10007-20W Jackson v. Comm’r, T.C. Memo. 2022-50 | May 12, 2022 | Vasquez, J. |...more

5/26/2022  /  Income Taxes , IRS , Rental Property , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Wolfson v. Commissioner | Collection Due Process and Review of Settlement Officer Performance of Duty

Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more

5/11/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Trust Fund Recovery Penalty (TFRP)

Tax Court in Brief | Podlucky v. Commissioner | $34M Jewelry in a Secret Room, Constructive Receipt, Innocent Spouse, and Putative...

Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more

5/11/2022  /  Abuse of Discretion , Income Taxes , IRS , Joint and Several Liability , Joint Tax Returns , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Mazzei v. Commissioner | Law of the Case, Prevailing Party, and “Substantially Justified”

Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more

5/10/2022  /  Income Taxes , IRS , Prevailing Party , Roth IRA , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Mighty v. Commissioner | Collection Due Process and 1,862 Days from Notice of Deficiency to Determination

Tax Litigation:  The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mazzei v. Comm’r, T.C. Memo 2022-43 |...more

5/10/2022  /  Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Sestak v. Commissioner | Badges of Fraud, Bribery, and Violation of Sharply Defined Public Policy

Tax Litigation:  The Week of April 25th, 2022, through April 29th, 2022 Sestak v. Comm’r, TC Memo. 2022-41| April 25, 2022 | Weiler, J. | Dkt. No. 17285-18...more

5/6/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Fraud , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Valentine v. Commissioner | Taxability of Military Pension and Disability Payments and Business Expense...

Tax Litigation:  The Week of April 25th, 2022, through April 29th, 2022 Valentine v. Comm’r, TC Memo. 2022-42| April 28, 2022 | Gustafson, J. | Dkt. No. 6724-19...more

5/6/2022  /  Business Expenses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Veterans Administration

The Doctrine of Constructive Receipts

Under the doctrine of constructive receipt, a cash-basis taxpayer who has an unrestricted right to receive income is treated as though they actually received the income–even if they did not.  Thus, even when a taxpayer has...more

5/4/2022  /  Federal Taxes , Income Taxes , IRS , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Sezonov v. Commisioner | Side Gigs and Passive Activities

Tax Litigation: The Week of April 18th, 2022, through April 22nd, 2022 Treece Financial Services Group, v. Comm’r, 158 T.C. No. 6 | April 19, 2022 | Kerrigan, J. | Dkt. No. 20850-19 Bindel v. Commissioner |April 20, 2022 |...more

4/29/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Pediatric Impressions Home Health, Inv. v. Comm’r | Common Law Employees, Section 530 Relief, and Penalties

Tax Litigation: The Week of April 11th, 2022, through April 15th, 2022 The REDI Foundation, Inc. v. Comm’r, T.C. Memo. 2022-34 |April 11, 2022 |Nega, J. | Dkt. No. 23715-18 Mihalik v. Comm’r | April 13, 2022 | Gustafson, D....more

4/19/2022  /  Employment Tax , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | The REDI Foundation, Inc. v. Commissioner | Statutory Employee, FICA, and Form 941

Tax Litigation: The Week of April 11th, 2022, through April 15th, 2022 Mihalik v. Comm’r | April 13, 2022 | Gustafson, D. | Dkt. No. 7881-19 Pediatric Impressions Home Health, Inc. v. Comm’r, T.C. Memo. 2022-35 | April 12,...more

4/19/2022  /  Federal Employees , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Metz v. Commissioner | Interplay of Criminal Tax, Civil Tax, and Civil Penalties

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022  /  Criminal Penalties , Income Taxes , Internal Revenue Code (IRC) , Reporting Requirements , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Webert v. Commissioner | Sale of Principal Residence

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022  /  Genuine Issue of Material Fact , Income Taxes , IRS , Joint Tax Returns , Tax Court , Tax Liability , Tax Returns

Tax Court in Brief | Norberg v. Commissioner | Currently Not Collectible

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Continuing Life Communities Thousand Oaks LLC v. Comm’r | IRS Discretion to Change Methods of Accounting and...

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022  /  Abuse of Discretion , Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Middleton v. Commissioner | Trust Fund Recovery Penalty Assessment and Collection Due Process

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4, 2022 |Panuthos, J. | Dkt. No. 20743-19S Salter v. Comm’r, T.C. Memo. 2022-9 |April 5, 2022 |Lauber,...more

4/14/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Trust Fund Recovery Penalty (TFRP)

Tax Court in Brief | Salter v. Commissioner | Substitute for Return and Itemized Deductions

Tax Litigation: The Week of April 4th, 2022, through April 8th, 2022 Middleton v. Comm’r, T.C. Memo. 2022-28 | April 4, 2022 |Kerrigan, J. | Dkt. No. 8158-19L Scholz v. Comm’r, T.C. Summary Opinion 2022-5 |April 4,...more

4/14/2022  /  Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Golditch v. Commissioner | Collection Due Process and Frivolous Arguments

Tax Litigation: The Week of March 28, 2022, through April 1, 2022 Addis v. Comm’r, T.C. Memo. 2022-24 | March 28, 2022 |Urda, J. | Dkt. No. 12140-20L Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt....more

4/5/2022  /  Due Process , Income Taxes , IRS , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Addis v. Commissioner | Collection Due Process and Frivolous Positions

Tax Litigation:  The Week of March 28, 2022, through April 1, 2022 Porter v. Comm’r, T.C. Memo. 2022-25 | March 28, 2022 |Greaves, J. | Dkt. No. 3544-21 Golditch v. Comm’r, T.C. Memo. 2022-26 | March 29, 2022 |Lauber, J. |...more

4/5/2022  /  Due Process , Income Taxes , IRS , Tax Court , Tax Levy , Tax Liability , Tax Planning , Tax Returns

Effectively Connected Income

Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more

3/30/2022  /  Capital Gains , Corporate Taxes , FDAP , FIRPTA , Income Taxes , IRS , Tax Planning , Tax Returns

Tax Court in Brief | Bunton v. Comm’r | Collection Due Process and “Last Known Address

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Cosio v. Comm’r, T.C. Memo. 2022-18 | March 9, 2022 | Weiler, J. | Dkt....more

3/15/2022  /  Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Levy , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

3/15/2022  /  Abuse of Discretion , Income Taxes , IRS , Jurisdiction , Tax Court , Tax Levy , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Hacker v. Com’r | Constructive Dividends, Unexplained Deposits, and Corporate Spending

Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No. 23074-19S Cosio v. Comm’r, T.C. Memo. 2022-18 | March 9, 2022 | Weiler, J. | Dkt. No....more

3/15/2022  /  Business Expenses , Capital Expenditures , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Estate of Kazmi v. Commissioner | Trust Fund Penalties and CDP Hearings

Tax Litigation:  The Week of February 28, 2022, through March 4, 2022 - Estate of Levine v. Comm’r, 158 T.C. No. 2 | February 28, 2022 | Holmes, J. | Dkt. No. 13370-13 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28,...more

3/7/2022  /  Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Trust Fund Recovery Penalty (TFRP)
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