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Abstract: 

This installment of Short Takes discusses recent rulings and other authority affecting (1) presidential power to impose tariffs; (2) non-recognition provisions; (3) realization (and related) issues; (4) passive activity losses; (5) hobby losses; and (6) capitalization, basis, and depreciation. Specific topics addressed include IRC Sec. 1400Z-2, qualified opportunity fund, gain deferral, IRC Sec. 104(a)(2), Doyle v. Comm’r, property incident to divorce, SALT refunds, Rev. Proc. 2019-18, economic development program grants, market facilitation program payments, Notice 2019-7, substance-over-form doctrine, Associates, LLC v. Comm’r, gambling losses, deductibility of marijuana-business expenses, Siegel v. Comm’r, conservation easements, education expenses, IRC Sec. 162 vs. IRC Sec. 212 deductions, theft losses, ordinary and necessary business expense, Connell v. Comm’r, Ballard v. Comm’r.

Keywords: tariffs, qualified opportunity fund, gain deferral, property incident to divorce, SALT refunds, economic development program grants, market facilitation program payments, substance-over-form doctrine, deductibility of marijuana-business expenses

Affiliations:  1: Journal of Taxation of Investments.