The Court
In Crane v. Commissioner (1947), the taxpayer inherited an apartment building that was subject to this type of mortgage debt.
What is a nonrecourse mortgage?
This Green Bay Packers player learned the hard way that winning a Corvette as a prize on December 31, 1961, counted as taxable income for 1962.
Who is Paul Hornung?
This 1961 Supreme Court case held that embezzled money counts as taxable income to the embezzler.
What is James v. United States?
Who is the current Secretary of the Treasury?
Who is Scott Bessent?
How many factors are there under Treas. Reg. 1.183-2(b) for Hobby Losses?
9 Factors
In Crane v. Commissioner (1947), when Mrs. Crane sold the apartment building and was relieved of the mortgage, the Supreme Court ruled she must include this in her “amount realized.”
What is the amount of the outstanding mortgage debt?
In Hess v. Commissioner (T.C. Summary Opinion 1994-79), respondent disallowed the deprecation of this in connection with petitioner's business as an independent contractor.
The principle that income must be recognized when a taxpayer has unrestricted control over funds is derived from this landmark 1941 case often cited in rental forgiveness contexts.
What is Hort v. Commissioner (1941)?
Which amendment to the U.S. Constitution gives Congress the power to levy an income tax without apportioning it among the states based on population?
What is the 16th Amendment?
What is the IRC defining gross income?
What is IRC 61(a)?
In Commissioner v. Tufts (1983), even if the property is worth less than the debt, the Supreme Court held the “amount realized” cannot be less than this.
What is the full unpaid principal amount of the nonrecourse loan?
In Craddock v. Commissioner (2023), even though bank statements were provided with charges highlighted (e.g., “fuel”, “tolls”), the court still held they were insufficient because they lacked this.
What is detailed supporting receipts or evidence separating business vs personal usage?
This 1987 Supreme Court case determined that a full-time gambler could deduct gambling-related expenses as business expenses under §162(a).
What is Commissioner v. Groetzinger?
Who is the current Commissioner of the IRS?
Who is Scott Bessent?
What is the IRC that covers the deductibility of expenses related to the business use of a taxpayer's home?
What is IRC 280A?
In Commissioner v. Glenshaw Glass (1955), in defining income, Chief Justice Earl Warren famously described it as “undeniable accessions to wealth, clearly realized, and over which the taxpayers have” what?
What is complete dominion?
One factor in favor of the Wondries (2023) was their use of a full-time foreman and formal accounting and payroll systems for the ranch — illustrating this factor about how the activity is conducted. (Hint: what are the factors for hobby loss)
What is the manner in which the taxpayer carries on the activity?
This 2023 tax court case underscores the importance of proper documentation and reasonable rental rates when claiming deductions for home rentals to ensure compliance with tax laws.
What is Sinopoli v. Commissioner (2023)?
What title of the United States Code is the Internal Revenue Code found?
What is Title 26?
Under IRS Publication 587, what are the two primary methods for calculating the home office deduction?
What is the Simplified Method and Actual Method?
In Arkansas Best Corp. v. Commissioner, the Court held that a taxpayer's motivation for purchasing an asset is irrelevant when determining if a loss is capital or ordinary. This principle was previously established in this 1955 case.
What is Corn Products Refining Co. v. Commissioner, 350 U.S. 46 (1955)?
This tax principle—central to Hornung v. Commissioner—states that income is considered received when it is made available to the taxpayer without substantial restriction.
What is the doctrine of constructive receipt?
In this case, the Court defined how to determine an employee’s “tax home” for the purpose of deducting travel and living expenses.
What is Commissioner v. Flowers?
Which IRS document provides an official interpretation by the IRS of the IRC, related statutes, tax treaties, and regulations?
What is a Revenue Ruling?
Under IRC 280A(c)(1), what are the two general requirements to be able to take the home office deduction?
1) dwelling is "exclusively used on a regular basis"
2) dwelling is considered the "principal place of business"