Aulisio v. Commr., T.C. Memo. 2024-29. (Marshall)

Green Gas Del. Statutory Tr. v. Commissioner, 147 T.C. 1, 65 (2016) (declining to apply the Cohan rule where only corroboration for documentary evidence was taxpayer's self-serving testimony)

Aulisio v. Commr., T.C. Memo. 2024-29. (Marshall)

Rosser v. Commissioner, T.C. Memo. 2001-79, 81 T.C.M. (CCH) 1467, 1471 (finding tax returns did not establish that the taxpayer had income and losses in the amounts reported on the returns)

Chappell v. Commr., T.C. Summary Opinion 2024-2. (Copeland)

Curphey v. Commissioner, 73 T.C. 766, 777-78 (1980) (holding that commuting expenses between a taxpayer's home office and a business location may be deductible if the home office is the taxpayer's principal place of business)

Gondal v. Commr., T.C. Memo. 2024-36. (Jones)

Magnon v. Commissioner, 73 T.C. 980, 993-94 (1980) ("Where a corporation confers an economic benefit on a shareholder without the expectation of repayment, that benefit becomes a constructive dividend, taxable to the shareholder, even though neither the corporation nor the shareholder intended a dividend.")

Gondal v. Commr., T.C. Memo. 2024-36. (Jones)

Castillo v. Commissioner, 84 T.C. 405, 408 (1985) ("The burden of proving fraud is on respondent, and he must do so by clear and convincing evidence.")

Hutchings v. Commr., . (Buch)

McKelvey v. Commissioner, T.C. Memo. 2002-63 (finding a taxpayer's research into and investigation of the business potential of creating a tree farm was not yet a functioning business.)

Hutchings v. Commr., . (Buch)

It is well established that the existence of a genuine profit motive is the most important criterium for finding that a given activity constitutes a trade or business.

Patel v. Commr., T.C. Memo. 2024-34. (Jones)

Crimi v. Commissioner, T.C. Memo. 2013-51, at *40 ("An expert witness may be allowed to testify in a proceeding before this Court when his or her scientific, technical, or other specialized knowledge might help us to understand the evidence or decide a fact in issue.")

Savannah Shoals, LLC v. Commr., T.C. Memo. 2024-35. (Goeke)

Lord v. Commissioner, T.C. Memo. 2010-196, slip op. at 5 (holding that the taxpayer did not substantially comply where the appraisal omitted the donation date, the date of the appraisal, and the fair market value of the donated property)

Savannah Shoals, LLC v. Commr., T.C. Memo. 2024-35. (Goeke)

Brooks v. Commissioner, T.C. Memo. 2022-122, at *17 (explaining that Congress "specifically" enacted the heightened substantiation requirements "to prevent the Commissioner from having to sleuth through the footnotes of millions of returns")

Standifird v. Commr., T.C. Memo. 2024-30. (Greaves)

Ernest S. Ryder & Assocs., Inc. v. Commissioner, T.C. Memo 2021-88, at *187-88 (finding fraudulent intent when a taxpayer created a complex business structure and assigned income to various entities to conceal income)

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

Balt. Gas & Elec. Co. v. United States, 817 F.2d 108, 116 (D.C. Cir. 1987) (noting that under the arbitrary and capricious standard of review, an agency is "required to respond to significant comments that cast doubt on the reasonableness of the rule the agency adopts")

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

Belair Woods, LLC v. Commissioner, T.C. Memo. 2018-159, at *10 (finding that the taxpayer did not substantially comply with reporting requirements when it failed to disclose cost or adjusted basis)

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

Bond v. Commissioner, 100 T.C. 32, 42 (1993) (finding that the taxpayer substantially complied with reporting requirements notwithstanding omission of appraiser's qualifications)

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

Lawrence v. Commissioner, 27 T.C. 713, 716-17 (1957) (observing that when one of our decisions is reversed by an appellate court, we must "thoroughly reconsider the problem in the light of the reasoning of the reversing appellate court and, if convinced thereby, . . . follow the higher court")

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

To be sure, "[t]he doctrine of stare decisis is important to this Court, and we are mindful of its role in [relevant cases]." Analog Devices, 147 T.C. at 443. But where, as here, we are faced with "issues on which a Court of Appeals has reversed our prior decision," see id., we are obligated to thoroughly reconsider our position, Lawrence, 27 T.C. at 716-17.

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

Stare decisis is "[t]he doctrine of precedent, under which a court must follow earlier judicial decisions when the same points arise again in litigation." Stare decisis, Black's Law Dictionary (11th ed. 2019). Courts have repeatedly taken the position that "[s]tare decisis is the preferred course because it promotes the evenhanded, predictable, and consistent development of legal principles, fosters reliance on judicial decisions, and contributes to the actual and perceived integrity of the judicial process." Payne v. Tennessee, 501 U.S. 808, 827 (1991).

Valley Park Ranch, LLC v. Commr., 162 T.C. No. 6 (2024). (Jones)

However, "any departure from the doctrine of stare decisis demands special justification." Arizona v. Rumsey, 467 U.S. 203, 212 (1984). This "special justification" is over and above the belief "that the precedent was wrongly decided." Halliburton Co. v. Erica P. John Fund, Inc., 573 U.S. 258, 266 (2014).

White v. Commr., T.C. Memo. 2024-31. (Fried)

Montgomery v. Commissioner, 122 T.C. 1, 8-9 (2004) (holding that taxpayers are allowed to challenge the underlying liability where the taxpayers self-assessed their underlying liability and did not receive a statutory notice of deficiency)

Wycoff v. Commr., T.C. Memo. 2024-37. (Lauber)

Even though petitioner is not a lawyer, a modest inquiry using an internet search engine would have led her to online sources showing the frivolous nature of these arguments. See Wnuck v. Commissioner, 136 T.C. 498, 504 (2011) ("Anyone with the inclination to do legal research . . . will confront such authorities."). The purpose of section 6673 is to compel taxpayers to think and to conform their conduct to settled principles before they file and litigate. Takaba v. Commissioner, 119 T.C. 285, 295 (2002)