Acquisition Indebtedness

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Sophy v. Commissioner; The limitations on the amounts that may be treated as acquisition and home equity indebtedness with respect to a qualified residence are properly applied on a per-residence rather than per-person basis.

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Commissioner v. Banks

Damages, including contingent fee amounts, are taxable income to litigants; a taxpayer may not anticipatorily assign the income to avoid tax liability for the income. Agent assignment contingent fee ordinary income principal.

King v. Commissioner

Noncustodial parents; dependency exemption deduction; lived apart from his child; last six months, receives more than half of his support from his parents during the year; custodial parent signs a written declaration.

Churchill Downs, Inc. v. Commissioner

Costs of invitation-only events used to publicize the kentucky derby are entertainment expenses; deductions for activities generally considered entertainment are limited to fifty percent, unless objectively integral to taxpayer business or occupation.

IHC Health Plans, Inc. v. Commissioner of Internal Revenue

Organization will not be considered charitable unless it is operated primarily to serve public rather than private interest.

Tax Reform

Congressional regulations; tax code.

Internal Revenue Code

Tax regulation; IRS regulations cartoon.

Money Subject to Repayment Contingency Is Not Gross Income

Westpac Pacific Food v. Commissioner; Cash advances in exchange for volume purchase commitments, subject to pro rata repayment if the volume commitments are not met, are not gross income when received; accrual basis.

Substitute For Ordinary Income Doctrine

Womack v. Commissioner; Under the substitute-for-ordinary-income doctrine, when a party receives a lump-sum payment for what otherwise would have been received, at a future time, as ordinary income, that lump sum payment isordinary income.

Property Settlement In Divorce Is Not A Taxable Event

Young v. Commissioner; A transfer of property is "incident to a divorce," and is thus a nontaxable event, if it is related to the cessation of the marriage; basis; nonrecognition rule.

Taxability of Student Income

Mayo Foundation for Medical Education and Research v. United States. Chevron analysis, not National Muffler analysis, applies in student income tax cases and social security tax issue. Chevron Deference.

Hobby Loss Rule

Engdahl v. Commissioner. When a taxpayer engages in an activity with the bona fide purpose of turning a profit, losses incurred from that activity are fully deductible. Horse breeding. Deductibility of business losses.

Sale Or Exchange

Bloomington Coca-Cola Bottling Co. v. Commissioner; The presence of a small amount of cash, to adjust certain differences in value of the properties exchanged, does not necessarily prevent the transaction from being considered an exchange.

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Acquisition Indebtedness

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