Tag: records

A Costly Miscalculation: Civil Fraud Penalties in Beleiu v. Commissioner

Cases, Income Tax, Tax, Tax Controversy, Tax Court

In Beleiu v. Commissioner, T.C. Memo. 2025-70, the Tax Court sustained civil fraud penalties under Internal Revenue Code (“IRC”) § 6663 against the taxpayer for tax years 2012 through 2014. While the deficiencies themselves were not disputed by the time of trial, the heart of the controversy centered on whether the underpayments stemmed from fraud.…
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Is Your Hobby Really “For Profit?” The Deductibility of Your Expenses Depends on It

Compliance, Income Tax, Tax, Tax Court

Generally, expenses related to activities that are not engaged in for profit are not deductible.[2] In a recent memorandum opinion[3], the United States Tax Court reiterated the criteria upon which the Court considers if an activity is engaged in for profit. While the recent decision was not a landmark case[4], it provides some cautionary guidance…
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