Individual income taxation

Cryptocurrency tokens a taxpayer received as staking rewards were includable in gross income in the year of receipt despite a restriction on the tokens’ transfer to another cryptocurrency wallet.

The IRS issued a passport notice certification of a “seriously delinquent tax debt” of more than $1.6 million in trust fund recovery penalties.

The Tax Court advised a taxpayer that if he filed a second petition, he probably would not have a chance for another review of the IRS’s collection action.

A district court declined to adopt a magistrate’s report recommending dismissal of a taxpayer’s complaint on the grounds that her refund claim was untimely.

The Tax Court affirmed an IRS Office of Appeals determination to sustain a proposed levy against a taxpayer who failed to file tax returns and did not respond to notices of deficiency that were mailed to her office.

The court held that it lacked subject-matter jurisdiction over a taxpayer’s refund claim that did not meet the full-payment rule set forth in Flora, 357 U.S. 63 (1958).

The Tax Court applied the hobby loss rules under Sec. 183 to disallow losses from a taxpayer’s ranch.