The text of the cases is in PDF format, so a Adobe Acrobat Reader is required. We've kept the key word list short to make searches easy. sale of subsidiary; interaction of constructive ownership rules. Tax Court with direct links to the full text at the Tax Court web site. The list below contains the case name, cite, the Code sections and key words for the issues in the case. 301; 302; 304; 318; property distributions; stock redemptions; redemption through use of related corporations; constructive ownership; dividends vs. The case name may differ from the official Tax Court name. Please note that the mention of an issue does not in any way imply the outcome. Tax Court at use their search engine (use the "Opinions Search" tab) to look for additional cases or words that we have not indexed. For example, if "fraud penalty " is mentioned, that only means the fraud penalty was an issue, not that it was imposed or rejected by the Court. 7491 (Burden of Proof); we have not listed it unless it was a significant issue. Their site contains full Tax Court cases (TC) and Tax Court Memorandum Opinions starting September 25, 1995 and Summary Opinions starting January 1, 2001. 6015; innocent spouse relief; equitable relief; knowledge; steps to mitigate tax problems made; payments under installment agreement. 61; 86; gross income definition; benefits income inclusion; social security income; instructions unclear no excuse. sale of subsidiary; interaction of constructive ownership rules. 301; 302; 304; 318; property distributions; stock redemptions; redemption through use of related corporations; constructive ownership; dividends vs.
162; 274; 6001; 6662; business expenses; business expense substantiation; required records; accuracy-related penalty; recordkeeping; documentation; cash fees paid to outside contractors.
71; 215; alimony; alimony; alimony payments allocable to unpaid child support.
469; 6662; 6664; passive loss limitations; accuracy-related penalty; penalty definitions and special rules; investment losses in limited partnership; carryforward of suspended passive activity losses.
For a similar synopsis of cases for prior years, go to: Tax Court Cases--2007 Tax Court Cases--2006 Tax Court Cases--2005 Tax Court Cases--2004 Merrill Lynch & Co.
6651; failure to file or pay; no reasonable cause for failure to file; evidence of inability to pay tax.
6221; 6226; 6230; 6662; partnership level tax treatment; partnership court review; partnership administrative changes; accuracy-related penalty; final partnership administrative adjustment; FPAA; partner-level defenses; sham transactions; son-of-BOSS; partner-level conduct.