The Tax Court’s December 18, 2025 ruling in Mark L. Fussell v. Commissioner delivers a stark warning to taxpayers who attempt to deduct loans to failed businesses as bad debts.
The Tax Court’s December 16, 2025 ruling in Mission Organic Center, Inc. v. Commissioner delivered a stark warning to state-legal marijuana businesses: the IRS’s collection power trumps even the most aggressive settlement offers when nondeductible §280E expenses are involved.
The stakes could not have been higher when the Tax Court denied a motion to dismiss a $45 million dispute over a conservation easement deduction; one that, if allowed, would have erased nearly $45 million in claimed charitable contributions, plus a 20% accuracy-related penalty...