Recently, there seems to have been a higher number of cases than usual coming down from courts regarding Tax Court jurisdictional issues. My colleague Parker Durham covered a few of them in a recent article.[1] In a recent case out of the Court of Federal Claims, yet another jurisdictional issue arose.[2] In the present case,…
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Taxpayers who are issued a notice of deficiency by the Internal Revenue Service (“IRS”) have ninety (90) days from the date such notice of deficiency is mailed to file a petition with the Tax Court for a redetermination of the deficiency.[1] Last year, the Tax Court dismissed several cases for lack of jurisdiction when the…
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Passive Activity Loss Rules Lead To Yet Another Taxpayer Loss In Court – Why Keeping Adequate Records Is Essential In a recently issued Memorandum Opinion[1], the United States Tax Court found that a husband and wife who owned and operated real estate investment properties were not entitled to deduct losses derived from properties owned in…
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In a recent Tax Court case[1], the Court held that the combined value of ten checks written prior to the decedent’s death, but cashed after his death, was included in the gross estate of the decedent. However, as discussed below, the IRS had conceded that three of the ten checks were not included in the…
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