2026-07-02
In June 2026, the Tax Court published 16 opinions, which included a total of 391 pages. Below are graphs for the month showing: (i) the top 15 code sections referenced, (ii) cases cited 5 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 June 2026 Tax Court cases referring to these types of principles or holdings.
Branch v. Commr., T.C. Memo. 2026-51. (Goeke)
It is well settled that taxpayers must file timely returns using the best information available to them and may file amended returns if necessary. Estate of Vriniotis v. Commissioner, 79 T.C. 298, 311 (1982).
Branch v. Commr., T.C. Memo. 2026-51. (Goeke)
Adams v. Commissioner, 82 T.C. 563, 567-70 (1984) (discussing division of community income when taxpayers were married for only a portion of a year)
Hee v. Commr., T.C. Memo. 2026-53. (Weiler)
Richardson v. Commissioner, 509 F.3d 736, 745 (6th Cir. 2007) (holding that fraud by one spouse "lifts the statute of limitations" for both)
Hee v. Commr., T.C. Memo. 2026-53. (Weiler)
Wycoff v. Commissioner, T.C. Memo. 2017-203, at *44 ("Special scrutiny is given in situations where a corporation is controlled by the employees to whom the compensation is paid because there is a lack of arm's-length bargaining.")
Hee v. Commr., T.C. Memo. 2026-53. (Weiler)
Ayria v. Commissioner, T.C. Memo. 2022-123, at *9 ("[I]t is well established that the costs of purchasing and maintaining ordinary street attire are not deductible merely because those clothes are worn to the office.")
Hee v. Commr., T.C. Memo. 2026-53. (Weiler)
Benes v. Commissioner, 42 T.C. 358, 382 (1964) ("Where fraud is alleged against a corporate taxpayer, the requisite proof of fraudulent intent is to be found in the acts of its officers, inasmuch as the corporation, being an artificial person created by law, can have no separate intent of its own apart from those who direct its affairs.")
Hee v. Commr., T.C. Memo. 2026-53. (Weiler)
Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662 (1987) ("As a general rule, the duty of filing accurate returns cannot be avoided by placing responsibility on a tax return preparer.")
Hee v. Commr., T.C. Memo. 2026-53. (Weiler)
In Hutchison v. Commissioner, 13 B.T.A. 1187, 1190 (1928), the Court held that massages were ordinary and necessary business expenses since the taxpayer was in the business of "stunt" acting and needed massages to be in excellent physical condition.
Paschall v. Commr., T.C. Memo. 2026-46. (Pugh)
Strashny v. Commissioner, T.C. Memo. 2020-82, at *8 (describing cryptocurrency as an asset to be considered for collection purposes in an administrative hearing)
Rising Rock Partners, LLC v. Commr., T.C. Memo. 2026-45. (Greaves)
Excelsior Aggregates, LLC v. Commissioner, T.C. Memo. 2024-60, at *31 ("The best evidence of a property's [fair market value] is the price at which it changed hands in an arm's-length transaction reasonably close in time to the valuation date.")
Rising Rock Partners, LLC v. Commr., T.C. Memo. 2026-45. (Greaves)
Estate of Rabe v. Commissioner, T.C. Memo. 1975-26 ("[A] prudent man will pay no more for a given property than he would for a similar property.")
Wells v. Commr., T.C. Memo. 2026-49. (Weiler)
Addis v. Commissioner, 374 F.3d at 887 ("The deterrence value of [a] total denial of a deduction [in the case of an improper [contemporaneous written acknowledgment]] comports with the effective administration of a self-assessment and self-reporting system.")
In June 2026, the IRS published 6 Announcements, Notices, Revenue Procedures, and Revenue Rulings, which included a total of 52 pages.
In June 2026, the IRS published 78 Written Determinations, which included a total of 452 pages.
