2025-11-03
In October 2025, the Tax Court published 18 opinions, which included a total of 284 pages. Below are graphs for the month showing: (i) the top 15 code sections referenced, (ii) cases cited 7 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 October 2025 Tax Court cases referring to these types of principles or holdings.
Berry v. Commr., T.C. Memo. 2025-109. (Pugh)
Berry v. Commissioner, T.C. Memo. 2021-52, at *10 ("Any amount claimed as cost of goods sold must be substantiated, and taxpayers are required to maintain records sufficient for this purpose.")
Green Family Delta Trust v. Commr., T.C. Memo. 2025-100. (Toro)
Chandler v. Commissioner, 142 T.C. 279, 293 (2014) ("The [Pension Protection Act of 2006, Pub. L. No. 109-280, 120 Stat. 780,] . . . eliminated the reasonable cause exception for gross valuation misstatements of charitable contribution property.")
Green Family Delta Trust v. Commr., 165 T.C. No. 7 (2025). (Toro)
Presley v. Commissioner, T.C. Memo. 2018-171, at *64-70 (analyzing the requirements for reasonable cause and declining to find reasonable cause because the taxpayer did not follow the advice given)
Middle Department Inspection Agency, Inc. v. Commr., T.C. Memo. 2025-99. (Jones)
West v. Commissioner, T.C. Memo. 2010-250 (finding that a taxpayer's arguments "[e]ach represent[] a claim that a provision of the tax law is unfair")
Mira Vista Homeowners Association, Inc. v. Commr., T.C. Memo. 2025-102. (Weiler)
Within the context of section 501(c)(3), the Supreme Court has held "operated exclusively" to mean that the presence of a single, substantial nonexempt purpose will preclude exempt status, regardless of the number or importance of exempt purposes. See Better Bus. Bureau of Wash., D.C., Inc. v. United States, 326 U.S. 279, 283 (1945).
Potts v. Commr., T.C. Memo. 2025-108. (Pugh)
Monteleone v. Commissioner, 34 T.C. 688, 692 (1960) ("For tax purposes, whether a theft loss has been sustained depends upon the law of the jurisdiction wherein the particular loss occurred.")
In October 2025, the IRS published 5 Announcements, Notices, Revenue Procedures, and Revenue Rulings, which included a total of 59 pages.
In October 2025, the IRS published 29 Written Determinations, which included a total of 213 pages.
