Small Business Taxes & Management

Tax Court Cases--2018


Small Business Taxes & ManagementTM--Copyright 2018, A/N Group, Inc.

 

Below is a list of the 2018 cases of the U.S. Tax Court with direct links to the full text at the Tax Court web site. The text of the cases is in PDF format, so an Adobe Acrobat Reader is required. The case name may differ from the official Tax Court name. We've substituted et ux. and et vir for the spouse's full name and et al. for additional petitioners. The list below contains the case name, cite, the Code sections and key words for the issues in the case. 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. Keep in mind that you can go to the U.S. Tax Court at www.ustaxcourt.gov and use their search engine (use the "Opinions Search" tab) to look for additional cases or words that we have not indexed. Their site contains full Tax Court cases (TC) and Tax Court Memorandum Opinions starting September 25, 1995 and Summary Opinions starting January 1, 2001.

For a similar synopsis of cases for prior years, go to:

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

 

New Additions - Week Ended January 20, 2018

Tax Court Cases

SIH Partners LLLP, Explorer Partner Corporation, Tax Matters Partner 150 T.C. No. 3 Sec. 1; 951; 956; tax imposed; amounts included in income of U.S. shareholders; investment earnings in U.S. property; controlled foreign corporations; CFCs; guaranteed loans made to U.S. persons; qualified dividend income.

 

Memorandum Decisions

Michelle Keel T.C. Memo. 2018-5 Sec. 36B; 61; credit for coverage under a qualified health plan; gross income definition; advance premium assistance tax credit; cancellation of debt income included to determine eligibility for credit.
John Anthony Glennon T.C. Memo. 2018-4 Sec. 61; 108; gross income definition; cancellation of indebtedness income; settlement of credit card debt; no claim of insolvency.

 

Summary Opinions

Pantano Baptist Church T.C. Summary Opinion 2018-3 Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; prior opportunity to contest penalties; failure to provide financial information.

 

Cumulative Cases - 2018

Tax Court Cases

SIH Partners LLLP, Explorer Partner Corporation, Tax Matters Partner 150 T.C. No. 3 Sec. 1; 951; 956; tax imposed; amounts included in income of U.S. shareholders; investment earnings in U.S. property; controlled foreign corporations; CFCs; guaranteed loans made to U.S. persons; qualified dividend income.
Kenneth William Kasper 150 T.C. No. 2 Sec. 7623; expenses of detection of underpayments and fraud; whistleblower awards; error by IRS Whistleblower Office; harmless error; whistleblower's information.
M. Rafizadeh 150 T.C. No. 1 Sec. 6038D; 6501; information with respect to foreign financial assets; limitations on assessment and collection; scope of Secv. 6501(e)(1)(A)(ii); six-year period of limitations; omission from gross income.

 

Memorandum Decisions

Michelle Keel T.C. Memo. 2018-5 Sec. 36B; 61; credit for coverage under a qualified health plan; gross income definition; advance premium assistance tax credit; cancellation of debt income included to determine eligibility for credit.
John Anthony Glennon T.C. Memo. 2018-4 Sec. 61; 108; gross income definition; cancellation of indebtedness income; settlement of credit card debt; no claim of insolvency.
Vincent M. Lorusso T.C. Memo. 2018-3 Sec. 6673; penalty for delay; Tax Court Rule 53; maintaining frivolous position; delay penalty; withdrawal of petition.
Joan Farr f.k.a. Joan Heffington T.C. Memo. 2018-2 Sec. 4958; taxes on excess benefit transactions; tax-exmept organization; disqualified person; Form 990-PF; private foundation; purchases for personal use.
Curtis Eugene Ankerberg T.C. Memo. 2018-1 6663; 6664; fraud penalty; definitions and special rules; badges of fraud; pattern of unreported income; failure to cooperate with IRS; failure to keep or produce records; overstated deductions.

 

Summary Opinions

Pantano Baptist Church T.C. Summary Opinion 2018-3 Sec. 6320; 6330; hearing on filing lien notice; hearing before levy; collection due process; prior opportunity to contest penalties; failure to provide financial information.
Evgeny Kiselev T.C. Summary Opinion 2018-2 Sec. 61; 894; gross income definition; income affected by treaty; Russian graduate student; stipend to fund scientific research; temporarily present in U.S.; recipient of grant.
Colin C. Bishop, Petitioner and Lisa Bishop, Intervenor T.C. Summary Opinion 2018-1 Sec. 6015; innocent spouse relief; knowledge of income; actual knowledge; failure to report retirement distributions; deposited in joint account.

 


Copyright 2018 by A/N Group, Inc. This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is distributed with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The information is not necessarily a complete summary of all materials on the subject.--ISSN 1089-1536


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--Last Update 01/120/18