CURRENT EDITION

Lessons Learned from the Tax Court: The Root of the Issue
When is a business really a business? As Supreme Court Justice Potter Stewart said in 1964, “I know it when I see it.” The US Tax Court, however, maintains a slightly less subjective standard. The Roots were pretty sure they were running a bona fide business; the IRS, however, didn’t share the sentiment. And since we’re reading about them in a segment called “Lessons Learned,” one should assume it did not go the way the Roots would have liked.
READ MORETAX COURT ROUNDUP – February 2025
When we enter upon a new Administration, we wonder at the shape of things to come. But surely since 1916, we have never had an incoming Administration promise us a repeal of the income tax and the reestablishment of the import tariff as the principal source of Federal funding. I would not, however, immediately cease to follow the proceedings of the US Tax Court.
Read MoreEditor’s Pick: BOI Reporting: A Game of Legal Ping-Pong
For tax professionals trying to guide their clients on Beneficial Ownership Information (BOI) reporting, the last few months have felt like watching a never-ending game of legal ping-pong. Deadlines have been set, overturned, reinstated, delayed, and challenged in court—leaving many businesses (and their advisors) unsure of when, or if, they need to file.
Read MoreHow to Advise on the EV Tax Credit
At one time, a federal tax credit toward the cost of an electric car seemed like a permanent idea to help fight pollution and climate change. Now, a political shift in the U.S. endangers the notion and, more to the point, makes advising clients tougher in a tighter timeframe. How and when can those clients interested in an electric car and the credit still secure a tax break?
Read MoreLeaving the United States, Part II: Renouncing Your Citizenship
In Part I of this 3-part series, we discussed the tax ramifications of living abroad, becoming an expat. In Part II, we go to the extreme by leaving America and renouncing our citizenship. And as you would guess, there are tax consequences to such an action. Before we step into renouncing our U.S. citizenship, we need to address how we can lose our citizenship.
Read MoreIs Student Loan Forgiveness Taxable? It Depends…
Is student loan forgiveness taxable? Yes. No. Maybe. Sometimes. It primarily depends on the student loan forgiveness program. But like everything else with student loans, there are a number of other factors at play. Why make it easy when you can thoroughly confuse taxpayers, federal student loan servicers and financial planners for years to come? Keep reading to learn when student loan forgiveness might be tax-free and how to prepare your clients for taxable loan forgiveness.
Read MoreAttack On Hobby Loss Regulations
Dr. Gary M. Schwarz and Marlee Schwarz overall lost in a recent Tax Court decision. It was a fascinating story. Dr. Schwarz, who had a very successful dental practice, also had a substantial amount of real estate. On some of the real estate, deer larger than usual for Texas roamed thanks to a fencing system that Dr. Schwarz had invented. This allowed for an ecotourism operation, which included hunting packages that generated a lot of revenue, but even more expenses. The silver lining of that cloud was the losses, characterized as farming, sheltered other income from dentistry and real estate.
Read More2025 Tax Surprises You Shouldn’t Overlook
There are a few tax rules new for 2025 that may catch some individuals and their tax advisers by surprise. These changes have not received lots of attention either because they are overshadowed by related changes that are more significant, or they were enacted a few years back with a future effective date that arrives in 2025. This article covers changes for 2025 that you will want to be sure to share with clients to avoid surprises at a later date.
Read MoreLeaving the United States, Part I: Expats
When Americans speak of leaving America, they generally are expressing a desire to live elsewhere in the world for cultural reasons or due to cost of living. These people are called expatriates, aka expats. For clarity, a mere visit to another country does not make you an expat. To be an expat, the move needs to be long-term and often includes working or retiring in the new country. Expats live somewhere outside the U.S., but still have a tax obligation to the U.S. and possibly the country they move to. That will be the focus of this article.
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CURRENT EDITION

Lessons Learned from the Tax Court: The Root of the Issue
When is a business really a business? As Supreme Court Justice Potter Stewart said in 1964, “I know it when I see it.” The US Tax Court, however, maintains a slightly less subjective standard. The Roots were pretty sure they were running a bona fide business; the IRS, however, didn’t share the sentiment. And since we’re reading about them in a segment called “Lessons Learned,” one should assume it did not go the way the Roots would have liked.

The Lessons From The Supreme Court Zuch Opinion
There is a great scene in the movie On The Basis Of Sex. The actors portraying Ruth Bader Ginsburg and her husband, Martin Ginsberg, a very high-level tax attorney, early in their careers are reading in separate rooms. He comes in with something he wants her to read and she snaps that she doesn’t read Tax Court cases. In that moment she showed her future as a Supreme Court Justice. Not many Tax Court cases reach the Supreme Court. So when one does it’s exciting. And, as it happens, Commissioner of Internal Revenue v Zuch contains some practical lessons worth considering.

Fractional Art Investing Is Real — How To Advise Your Clients On The Tax Consequences
In mid-November a portrait of a young Vietnamese woman by the artist Gustav Klimt, which was part of the estate of the late Leonard Lauder (the cosmetics billionaire), was sold at a Sotheby’s auction for $236.4 million. It set the record for the most expensive work of modern art ever sold at auction according to Bloomberg. That’s probably out of reach for most of our clients. But what if they could join together to buy an interest in the painting with an entity holding the asset? That’s the idea behind the burgeoning fractional art market. While, in general, the art market has been struggling for a few years, the fractional art market has been expanding. According to the website Digital Original, “Fractional art ownership is no longer a niche concept – it’s a growing investment trend that’s accessible, flexible, and supported by cutting-edge technology.” What, you may be asking, does this have to do with taxes? It may be more than you think for your high-net-worth clients. As a trusted advisor it’s important that you are aware of both the types of investment opportunities your clients may be buying into and the tax consequences.








