United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court, sustaining additions to tax and accuracy-related penalties, held that a couple may deduct some wage and contract services expenses and mortgage interest expenses related to the husband’s law practice but that due to lack of substantiation wasn’t entitled to deductions for other expenses or net operating losses.

CHARLES P. KARCH AND PATRICIA L. KARCH,
Petitioners
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

Filed October 22, 2013

UNITED STATES TAX COURT

T.C. Memo. 2013-237

 

United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court, in a memorandum opinion sustaining addition to tax and negligence penalties, concluded that a musician/music teacher substantiated vehicle expenses related to his performance activities under the Cohan rule but that the IRS properly disallowed or recharacterized various other expense deductions claimed on schedules A and C.

Joseph D. Scully, Jr., pro se.

Thomas D. Yang, for respondent.

T.C. Memo. 2013-229

UNITED STATES TAX COURT

Filed September 30, 2013

 

United States Tax Court Decision for the Week – You be the Judge

A recent Tax Court decision was reported that may be of interest to individuals potentially dealing with tax litigation. J. Frank Best, Certified Public Accountant and United States Tax Court Practitioner, works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for our clients.

The Tax Court held that an attorney who has been admitted to practice before the court had unreported income, wasn’t entitled to deductions or credits beyond those allowed in an IRS deficiency notice, and is liable for additions to tax for failure to timely file a return and for failure to pay estimated tax.

SAMUEL KORNHAUSER,
Petitioner
v.
COMMISSIONER OF INTERNAL REVENUE,
Respondent

T.C. Memo. 2013-230