Jasper L. Cummings, Jr.

Hobby Losses and Movies: Lee and William Storey v. CIR, T.C. Memo. 2012-115 (4/19/2012)
Jasper L. Cummings, May 1, 2012
This new Tax Court decision allows a lawyer to avoid the hobby loss rule and currently deduct the costs of making a documentary movie that might be said to be “for fun,” and interprets for the first time Section 181 (enacted in 2004), which permits deduction rather than capitalization...

Closely Held Section 305 Issues
Jasper L. Cummings, March 5, 2012
Section 305 is an antique weapon that mostly misfires. Its roots go back to the very beginnings of the income tax, when the courts were trying to figure out what was income. Stock distributions caused problems because they had value and looked like income, but everyone understood that a pro rata...

Quick Peek Discovery: Salem Financial, Inc. v. United States, No. 10-192T (Claims Court Jan. 18, 2012)
Jasper L. Cummings, February 2, 2012
A U.S. Court of Federal Claims judge has rejected some privilege claims and directed the taxpayer to allow the government lawyers a “quick peek” at other documents the taxpayer does not want to turn over in discovery. In the course of this opinion, most of the possible issues that can...