Taxes March 24, 2026
Can a Taxpayer Recover Attorney Fees When Challenging the IRS?
Even if you’re the prevailing party in the matter, you still must pay the tab if the IRS shows that it was substantially justified in taking its position.
Taxes March 10, 2026
Law Professor Learns Harsh State Income Tax Lesson
A law school professor working from home contested a state law requiring him to pay tax to a different state than the one where he resides.
IRS March 2, 2026
Tax Court Grants Tax Relief for Unknowing Spouse
If a married couple files a joint tax return, they are “in it together” as far as federal income tax liability is concerned. However, as shown in a new case, an “innocent spouse” may be entitled to equitable relief due to special circumstances.
Taxes February 13, 2026
Tax Court Slams Brakes on Charitable Deduction
The Tax Court immediately nixed the deduction because of the inadequate substantiation and the lack of any appraisal for high-income items.
Taxes December 29, 2025
Tax Court Affirms Nature of Constructive Dividends
In a new case, Alioto, TC Memo 2025-125, 12/4/25, a C corporation paid the personal expenses of its main shareholder, with adverse tax consequences.
Taxes December 6, 2025
Tax Court Rules No Tax-Free Pass on S Corp Income
With an S corporation, the owners are of the business essentially taxed like partners in a partnership. In contrast, C corporation owners must cope with “double taxation” where income is first taxable to the corporation and then distributions are taxed to the owners.
Taxes June 10, 2025
Don’t Pass Up Form 8300 Filing Requirements
A company that sells automobiles through an auction house claimed a software glitch outside of its control led to the non-filing of Form 8300. Did the Tax Court give the company a pass?
Taxes May 16, 2025
Tax Court Delivers Bad News to Tardy Taxpayer
In a new case, an office mix-up authorizing the wrong FedEx service resulted in a missed tax deadline. The Tax Court addressed whether the “equitable tolling” doctrine grants the taxpayer a reprieve.
Taxes May 7, 2025
The Tax Blotter – May 2025
Along with casualty losses, deductions for personal theft losses remain suspended at least through the end of the year, although there are certain exceptions.
Taxes April 28, 2025
Taxpayer Fails Test on Frivolous Tax Claim
Tax Court judges are notoriously a no-nonsense bunch. They consistently deny claims by taxpayers that are considered to be “frivolous” in nature.
Payroll March 31, 2025
Taxpayer Absorbs Full Tax Weight on Hardship Distribution
If a taxpayer is in dire need, the taxpayer may choose to take a “hardship distribution” from a qualified retirement plan. However, as shown in a new case, Campana, TC Memo 2025-23, 3/19/25, this doesn’t absolve any tax liability.
Taxes March 7, 2025
Can a U.S. Tax Court Decision Be Appealed?
Even though the Tax Court is commonly thought of as the forum of last resort for appealing tax bills and other IRS issues, there is a way to appeal a Tax Court ruling. However, the chances of success of these appeals are often relatively low.