2025-04-10
In March 2025, the Tax Court published 18 opinions, which included a total of 265 pages. Below are graphs for the month showing: (i) the top 15 code sections referenced, (ii) cases cited 10 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 March 2025 Tax Court cases referring to these types of principles or holdings.
Anderson v. Commr., T.C. Memo. 2025-26. (Ashford)
Leavell v. Commissioner, 104 T.C. 140, 155-59 (1995) (attributing income to individual taxpayer where facts and circumstances did not establish he was an employee of his personal service corporation)
Anderson v. Commr., T.C. Memo. 2025-26. (Ashford)
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986) (stating that we are not bound to accept a taxpayer's self-serving testimony)
Ballew v. Commr., T.C. Memo. 2025-25. (Nega)
Gitlitz v. Commissioner, 531 U.S. 206, 209 (2001) ("Subchapter S allows shareholders of qualified corporations to elect a 'pass-through' taxation system under which income is subjected to only one level of taxation.")
CF Headquarters Corporation v. Commr., 164 T.C. No. 5 (2025). (Kerrigan)
Congress enacted section 118 to codify existing judicial doctrine that treated certain transfers to corporations from nonshareholders as capital contributions rather than as income to the corporation.
Christiansen v. Commr., T.C. Memo. 2025-21. (Landy)
Lewis v. Commissioner, 523 F.3d 1272, 1274-76 (10th Cir. 2008) (discussing how the Paperwork Reduction Act does not support arguments against the imposition of tax liability)
Christiansen v. Commr., T.C. Memo. 2025-21. (Landy)
Woods v. Commissioner, 91 T.C. 88, 90 (1988) (rejecting contentions by the taxpayer that the federal income tax system is voluntary in the sense that it is optional)
Christiansen v. Commr., T.C. Memo. 2025-21. (Landy)
Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984) (per curiam) ("We perceive no need to refute these arguments with somber reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.")
Nwafor v. Commr., T.C. Memo. 2025-27. (Urda)
Rice v. Commissioner, T.C. Memo. 1967-54 ("Insofar as this deduction consisted of [the taxpayer's] estimate of the monetary value of his own time devoted to the litigation indulged in by him, it is obvious that it did not constitute an expense 'paid or incurred' by him.")
Nwafor v. Commr., T.C. Memo. 2025-27. (Urda)
IBP, Inc. v. Alvarez, 546 U.S. 21, 34 (2005) ("[I]dentical words used in different parts of the same statute are generally presumed to have the same meaning . . . .")
Nwafor v. Commr., T.C. Memo. 2025-27. (Urda)
Harwood v. Commissioner, T.C. Memo. 2022-8, at *13 ("As a general rule, a cash basis taxpayer deducts expenses for the year of payment.")
In March 2025, the IRS published 7 Announcements, Notices, Revenue Procedures, and Revenue Rulings, which included a total of 77 pages.
In March 2025, the IRS published 42 Written Determinations, which included a total of 244 pages.
