2025-03-26
In February 2025, the Tax Court published 10 opinions, which included a total of 179 pages. Below are graphs for the month showing: (i) the top 15 code sections referenced, (ii) cases cited 5 or more times, (iii) the number of opinions by judge, and (iv) the number of pages by judge.
I am always interested in learning well-established tax principles. Often, court cases will explicitly indicate that a tax principle is well established or well settled. Or the court may concisely state the holding of a prior case in a parenthetical. Below are excerpts from the February 2025 Tax Court cases referring to these types of principles or holdings.
Blum v. Commr., T.C. Memo. 2025-18. (Goeke)
Many of the documents in the administrative file and most of the documents labeled as transcripts of [the taxpayer's] account are full of abbreviations, alphanumeric codes, dates, and digits that are indecipherable and unintelligible without additional explanation.
Blum v. Commr., T.C. Memo. 2025-18. (Goeke)
It is well settled that outside basis is an affected item that must be determined at the partner level.
Blum v. Commr., T.C. Memo. 2025-18. (Goeke)
Collateral estoppel is a judicially created doctrine that is intended "to protect litigants from the burden of relitigating an identical issue and to promote judicial economy by preventing unnecessary or redundant litigation."
Brown v. Commr., T.C. Memo. 2025-17. (Jenkins)
[W]e will uphold a notice of determination of less than ideal clarity if the basis for the determination may reasonably be discerned . . . .
Brown v. Commr., T.C. Memo. 2025-17. (Jenkins)
[P]rovisions of the [Internal Revenue Manual] do not carry the force and effect of law or confer rights on taxpayers.
Langlois v. Commr., T.C. Memo. 2025-12. (Urda)
[I]t is well established that the costs of purchasing and maintaining ordinary street attire are not deductible merely because those clothes are worn to the office.
Langlois v. Commr., T.C. Memo. 2025-12. (Urda)
[A] partner's payment of partnership expenses can be treated as a contribution to the partnership, with the paying partner then entitled to deduct his allocable share of the expense.
In February 2025, the IRS published 5 Announcements, Notices, Revenue Procedures, and Revenue Rulings, which included a total of 35 pages.
In February 2025, the IRS published 50 Written Determinations, which included a total of 273 pages.
