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Tax Court News & Case Summaries

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newsIRS Written Determination

IRS Rules Nonprofit’s Income Excludable Under § 115(1) and Contributions Deductible Under § 170(c)(1)

The IRS ruled that a county-created nonprofit’s income from blighted property reclamation qualifies for exclusion under § 115(1) of the Internal Revenue Code, which exempts income derived from essential governmental functions accruing to a political subdivision.

PLR-111952-25
newsIRS Written Determination

IRS Rules on Patronage-Sourced Income for Taxable Rural Telephone Cooperative

The IRS has ruled that a rural telephone cooperative may exclude from its consolidated gross income the portion of gain from the sale of a partnership interest that is allocable to patrons’ prior use of the partnership’s network.

PLR-103331-21
newsIRS Written Determination

IRS Rules on Tax-Free Liquidation and Exemption for Tribal-Owned Corporations Under OIWA

A tribal-owned corporation petitioned the IRS for certainty on a proposed restructuring under the Oklahoma Indian Welfare Act (OIWA), seeking to avoid a potential multimillion-dollar tax liability tied to a liquidation into a tax-exempt tribal entity.

PLR-101163-25
newsUS Tax Court

Royalty Management Insurance Company, Ltd. v. Commissioner & Sheperd v. Commissioner

The Tax Court just handed down a landmark ruling that could reshape the microcaptive insurance industry; one that wipes out $1,099,900 in claimed deductions, slaps the taxpayers with a 40% accuracy-related penalty, and asserts sweeping authority over a tax structure Congress explicitly incentivized.

Docket Nos. 3823-19, 4421-19
newsUS Tax Court

Tibor Gyarmati v. Commissioner of Internal Revenue: Court Upholds $1.2M Deficiency and Penalties for Undocumented Improvements and Furnishings

The Tax Court has delivered a stark reminder to taxpayers: undocumented basis claims are a losing bet. In Tibor Gyarmati v. C. Memo.

33671-21
newsUS Tax Court

Hancock County Land Acquisitions, LLC v. Commissioner of Internal Revenue

183 million; after concluding the claimed value was inflated by a jaw-dropping $178 million. The court’s opinion, issued March 26, 2026, marks another decisive blow to syndicated conservation easements (SCEs), a transaction the IRS has long branded as an abusive tax shelter.

12385-20
newsUS Tax Court

Michael Smith v. Commissioner of Internal Revenue

The Tax Court’s March 19, 2026 ruling in Michael Smith v. C. Memo. 2026-25) delivered a sharp reminder to Social Security Disability Insurance (SSDI) recipients: taxability hinges on the year benefits are received, not whether they must later be repaid.

1044-25
newsUS Tax Court

Tax Court Denies Partnership’s Due Process Challenge to BBA Audit Regime

8 million in potential tax liabilities, penalties, and constitutional due process rights.

577-24
newsUS Tax Court

Arbor Vita Corp. v. Commissioner: Suspended Corporate Status Dooms Tax Court Petition

In 2025, the IRS issued a Notice of Determination sustaining a federal tax lien against Arbor Vita Corporation for unpaid 2017 unemployment taxes and civil penalties exceeding $200,000.

4172-25L
newsUS Tax Court

Mammoth Cave Property, LLC v. Commissioner: IRS Wins on Timely FPA Despite Partnership Representative Errors

The stakes couldn’t have been higher. C. Memo. 2026-XX) exposed a critical vulnerability in the IRS’s audit procedures; and the court’s willingness to overlook procedural missteps when the stakes involve substantial tax liabilities.

5401-24
newsUS Tax Court

Kavan Shaban v. Commissioner of Internal Revenue: Passport Certification Upheld Despite Embezzlement Claims

The stakes couldn’t be higher for Kavan Shaban. The Maryland doctor faces the imminent loss of his passport after the IRS certified his $147,274 tax debt as "seriously delinquent" under Internal Revenue Code § 7345, a provision that empowers the agency to notify the State...

4885-25P
newsUS Tax Court

Tax Court Slashes $31.9M in Conservation Easement Deductions, Imposes 40% Gross Valuation Misstatement Penalties

S. 9 million in conservation easement deductions for 2016.

Docket Nos. 12304-20, 12517-20, 13271-20, 13663-20
newsUS Tax Court

Tax Court Rules on Zero Basis for Contributed Promissory Notes in Disregarded Entity Context

The Tax Court’s March 2 decision in Continental Grand Limited Partnership marks a significant shift in how partnerships and disregarded entities handle foreign currency translation losses under Section 987.

859-22
newsUS Tax Court

Tracey Yvonne Lucas v. Commissioner of Internal Revenue

The Tax Court’s decision in Lucas v. Commissioner delivers a stark warning to home-based business owners: $15,654 in deficiencies and $3,131 in penalties sustained in full.

25645-22
newsUS Tax Court

Otay Project LP v. Commissioner: Court Rejects $743 Million Basis Deduction in Partnership Termination Dispute

S. Tax Court issued its February 23, 2026 memorandum opinion in Otay Project LP v. C. Memo. 2026-21). 8 million deduction claimed by Otay Project LP (OPLP) following the termination of its partnership, a figure that would have otherwise erased nearly all taxable income for the short 2012 tax year.

Docket No. 6819-20
newsUS Tax Court

Pesarik v. Commissioner: Tax Court Rejects Principal Residence Exclusion and Adjusts Basis for Property Sales

The stakes couldn’t have been higher for Jeffrey Pesarik. The IRS hit him with a $255,281 deficiency for unreported gains from two property sales in 2020, along with a $54,355 accuracy-related penalty.

23859-22
newsUS Tax Court

Tax Court Bars Challenges to Penalties After Declined IRS Appeals Opportunity

The Tax Court delivered a resounding affirmation of its authority to limit liability challenges under § 6330(c)(2)(B); a provision that bars taxpayers from re-litigating tax liabilities they previously had the chance to dispute.

Docket Nos. 17038-18L, 17535-18L
newsUS Tax Court

North Donald LA Property, LLC v. Commissioner of Internal Revenue

S. 8% to just $175,824. In a sweeping rejection of the taxpayer’s valuation methodology, Judge Lauber’s memorandum opinion in North Donald LA Property, LLC v. C. Memo. 055 million in syndication fees.

24703-21
newsUS Tax Court

Tax Court Upholds $42K in Deficiencies and Fraud Penalties Against Tax Preparer for Unsupported Deductions

The stakes couldn’t have been higher in Goodwill-Oikerhe v. D. in progress saw his own tax filings scrutinized; and the Tax Court wielded its full authority to impose $42,054 in deficiencies and $31,495 in fraud penalties for tax years 2015–2017.

Docket No. 20144-19
newsUS Tax Court

El v. Commissioner: IRS Recovers $15,764 Erroneous Child Tax Credit Refund

In El v. S. Tax Court ruled in favor of the IRS, allowing it to claw back a $15,764 refund issued to a New Jersey taxpayer due to a computer error in calculating the Additional Child Tax Credit (ACTC).

15597-23
newsUS Tax Court

Clinco v. Commissioner: AI Hallucinations, Unreported Income, and Unsubstantiated Depreciation

The stakes couldn’t have been higher when Peter Clinco, a well-regarded real estate attorney, and his wife filed their 2015 joint return. 8 million in restaurant income and improperly claimed $400,000 in depreciation deductions on rental properties. The case, now finalized in Clinco v. C. Memo.

8077-23
newsUS Tax Court

Tax Court Rules Against Taxpayer in APTC Repayment Dispute: $11,436 Deficiency Upheld

When Ingrid Maria Persson of California learned she owed the IRS $11,436 for tax year 2019; a sum equal to the advance premium tax credit (APTC) she had received; the Tax Court’s February 9, 2026 ruling in Persson v. C.

8380-22S
newsUS Tax Court

Kolar v. Commissioner: Tax Court Rejects IRS Hobby Loss Challenge, Upholds $205K in Ranch Deductions

The Tax Court’s February 9 ruling in Kolar v. C. Memo. 2026-15) delivered a decisive victory for Kenward F. , upholding $205,514 in farm expense deductions despite the IRS’s aggressive challenge under Section 183, the so-called "hobby loss" rule.

Docket No. 5482-19
newsUS Tax Court

Tax Court Denies Treaty Exemption for Russian Scientist’s Compensation, Upholds IRS Deficiency

The Tax Court’s ruling in Baturin v. Commissioner delivers a stark message to nonresident researchers: $22,229 in unpaid taxes hinges on whether compensation is a tax-exempt grant or taxable wages; and the court will not bend treaty language to spare taxpayers from the...

14796-14
newsUS Tax Court

Mossy Flats Property, LLC v. Commissioner of Internal Revenue: Supervisory Approval Under Section 6751(b)

S. Tax Court granted the IRS’s motion for partial summary judgment on supervisory approval in Mossy Flats Property, LLC, a case that could redefine how the agency polices its own penalty procedures. 1 million in accuracy-related penalties under Section 6662(h) for gross valuation misstatements.

11538-24
newsUS Tax Court

Sullivans’ Profit Motive Dispute: Tax Court Allows Deductions for Software Development and Partial Home Construction Expenses

2 million tax deficiency and penalties hinged on whether the Sullivans’ software development and real estate ventures were legitimate businesses; or merely expensive hobbies. S. 71-acre parcel were engaged in for profit. 89-acre parcel, deeming those activities not for profit.

15625-22
newsUS Tax Court

Walker Church Greene 819, LLC et al. v. Commissioner of Internal Revenue

The stakes in Walker Church Greene 819, LLC v. 9 million charitable contribution deduction for a conservation easement donation. The IRS seeks full disallowance, while 40 partners challenge a settlement reducing penalties from 40% to 10%. C. Memo.

645-22
newsUS Tax Court

Tax Court Denies Majority of Research Credits in Complex Poultry Farming Case, Upholds Penalties on Substantiation Grounds

S. Tax Court delivered its February 3, 2026, ruling in Gary C. George and Robin A. George v. Commissioner. 47 million in claimed research credits under Section 41, the federal incentive for increasing research activities, along with $201,319 in accuracy-related penalties.

Docket Nos. 27494-16, 21889-21
newsUS Tax Court

Tax Court Upholds IRS Collection Action Despite Late Petition, But Grants Equitable Tolling in CDP Case

S. Tax Court has carved out fresh authority to bypass jurisdictional hurdles in collection disputes, handing taxpayers a rare lifeline in Salazar v. C. Memo. 2026-9).

14285-23L
newsUS Tax Court

Aventis, Inc. and Subsidiaries v. Commissioner of Internal Revenue

S. Tax Court’s January 28, 2026 ruling in Aventis, Inc. v. 47 million in claimed tax benefits for tax years 2008–2011.

11832-20