Proving ‘Material Participation’ In Today’s Digital Age

The fight over who meets the definition of a “real estate professional” is not a new one. Fortunately, the taxpayer’s burden for satisfying that definition has only been eased by the expansion of digital tools available for tracking time. That being said, the United States Tax Court’s (Court’s) memorandum opinion in Hairston v. Comm’r of [...]

Emphasizing Physical Injuries In Settlement Agreements

The United States Tax Court (Court) recently issued a decision highlighting, yet again, the importance of clear drafting in settlement agreements. In Doyle v. Comm’r of Internal Revenue, T.C. Memo. 2019-8, the Court held that the taxpayer could not exclude amounts, pursuant to Internal Revenue Code § 104(a)(2), that he received from a settlement agreement. [...]

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