Today in Tax Court

By: Roger Ledbetter
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  • Summary

  • Come for the stories, stay for the alpha. I read recent Tax Court cases and summarize them to share thoughts on: how the IRS thinks about taxes, relevant tax law, historical court cases you should know about.
    Copyright 2023 All rights reserved.
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Episodes
  • Episode 9 - Ogden v. Commissioner

    Episode 9 - Ogden v. Commissioner
    Jan 31 2025

    One of my favorite topics - Operating Agreement tax allocation language!

    Maybe one of the biggest things to get right when talking about partnership tax returns is the allocation of income and loss. It's not as straight forward as many think it is.

    In Ogden v. Commissioner (from 1985), the taxpayer had the majority of her loss taken away after the Court saw the operating agreement didn't have the right language.

    Enjoy!
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    22 mins
  • Episode 8 - Franklin v. Commissioner

    Episode 8 - Franklin v. Commissioner
    Jan 23 2025

    A sheriff in Alabama gets caught "embezzling" from inmate food funds.

    But the argument is made that she only made a bad investment (she did) - and she avoids paying tax on the majority of the money taken.

    A wild story with few twists and turns - enjoy!
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    19 mins
  • Episode 7 - Sehati v. Commissioner

    Episode 7 - Sehati v. Commissioner
    Jan 17 2025

    A desperate LinkedIn accounting job posting + a 40 year old treasure box + mall kiosks = a wild story.

    This case highlights how IRS auditors approach auditing small businesses, and what not to tell an IRS agent to get every entity in the org. chart audited.

    It winds up with a $3.8 million income hit to the taxpayers.
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    28 mins

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