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TaxGPT · cited answer

Can a client deduct a home office used for a side consulting business if they're also a W-2 employee?

The W-2 employee deduction is suspended through 2025 under TCJA, but the self-employed activity is independent. For the consulting business, §280A allows a deduction where the space is used regularly and exclusively as the principal place of that business — judged on the facts, not the square footage alone…

§280A IRS Pub. 587 Soliman v. Commissioner Hamacher v. Comm'r

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Farhy v. Commissioner

160 T.C. No. 6 · United States Tax Court

For Taxpayer

Issue

Whether the IRS has statutory authority to assess the initial and continuation penalties imposed by §6038(b)(1) and (2) for failure to file Forms 5471 required by §6038(a) — and if not, whether respondent may proceed by levy under §6330 to collect them.

Rule

§6201(a) authorizes assessment of taxes "including interest, additional amounts, additions to the tax, and assessable penalties," and §§6665(a)(1) and 6671(a) provide that specified chapter-68 penalties are assessed and collected in the same manner as taxes. But taxes and penalties remain distinct absent a provision treating them alike; where Congress prescribes a civil penalty without specifying a mode of recovery, 28 U.S.C. §2461(a) makes a civil action the mechanism.

Analysis

Though petitioner willfully failed to file the required Forms 5471 and the IRS recorded §6038(b) assessments, no statute expressly authorizes those penalties to be assessed in the same manner as taxes. The court contrasted §6038(b) with the many provisions where Congress specifically granted assessment authority, rejected the argument that all non-deficiency penalties are necessarily "assessable," and held that §2461(a) leaves civil action — not administrative assessment and levy — as the recovery route. The settlement officer's §6330(c)(1) verification was therefore legally incorrect.

Conclusion

Respondent lacked statutory authority to assess the §6038(b)(1) and (2) penalties; because the assessments were unauthorized, the penalties could not be collected by the proposed §6330 levy. Decision entered for petitioner.

Code Sections

§6038(a) §6038(b)(1) §6038(b)(2) §6201(a) §6330 §6330(c)(1) §6665(a)(1) §6671(a)

Cases Cited in This Opinion

Smith v. Commissioner133 T.C. 424 Grajales v. Commissioner156 T.C. 55 ↗West Virginia v. EPA142 S. Ct. 2587

The two Tax Court cases open as their own memos . West Virginia v. EPA is a Supreme Court decision — outside the Tax Court corpus, so it links out rather than opening a memo.