Filed: Dec. 14, 2018
Latest Update: Mar. 03, 2020
Summary: United States Court of Appeals For the Eighth Circuit _ No. 17-3804 _ Naren Chaganti lllllllllllllllllllllAppellant Commissioner of Internal Revenue lllllllllllllllllllllAppellee _ Appeal from The United States Tax Court _ Submitted: October 29, 2018 Filed: December 14, 2018 [Unpublished] _ Before LOKEN, BENTON, and SHEPHERD, Circuit Judges. _ PER CURIAM. Naren Chaganti appeals from a tax court decision upholding the Commissioner’s determination finding him liable for income tax deficiencies and
Summary: United States Court of Appeals For the Eighth Circuit _ No. 17-3804 _ Naren Chaganti lllllllllllllllllllllAppellant Commissioner of Internal Revenue lllllllllllllllllllllAppellee _ Appeal from The United States Tax Court _ Submitted: October 29, 2018 Filed: December 14, 2018 [Unpublished] _ Before LOKEN, BENTON, and SHEPHERD, Circuit Judges. _ PER CURIAM. Naren Chaganti appeals from a tax court decision upholding the Commissioner’s determination finding him liable for income tax deficiencies and ..
More
United States Court of Appeals
For the Eighth Circuit
___________________________
No. 17-3804
___________________________
Naren Chaganti
lllllllllllllllllllllAppellant
Commissioner of Internal Revenue
lllllllllllllllllllllAppellee
____________
Appeal from The United States Tax Court
____________
Submitted: October 29, 2018
Filed: December 14, 2018
[Unpublished]
____________
Before LOKEN, BENTON, and SHEPHERD, Circuit Judges.
____________
PER CURIAM.
Naren Chaganti appeals from a tax court decision upholding the
Commissioner’s determination finding him liable for income tax deficiencies and
penalties related to his 2006 and 2007 taxes.
Following a careful review, see DKD Enter.v. C.I.R.,
685 F.3d 730, 734 (8th
Cir. 2012) (tax court’s legal conclusions are reviewed de novo and its factual findings
for clear error; unless claimed deductions come clearly within scope of statute, they
are not to be allowed); see also Parrish v. C.I.R.,
168 F.3d 1098, 1102 (8th Cir. 1999)
(tax court’s finding that taxpayer is liable for accuracy-related penalties under 26
U.S.C. § 6662 is reviewed for clear error). Although we do not affirm the tax court’s
conclusion that the mere fact that petitioner was ordered to pay opposing counsel
attorney’s fees under [28 U.S.C.] § 1927, demonstrates that those amounts were not
ordinary and necessary to the practice of law, for reasons explained by the tax court
we conclude that the Commissioner’s determination of income tax deficiencies and
penalties was correct. Critically, the district judge’s sanctions order details the facts
in this case which show that the payments are not deductible under the Internal
Revenue Code §§ 162(f) and 165(a). See Katoch v. Mediq/PRN Life Support
Services, Inc.,
2007 WL 2434052 at *6-10 (E.D. Mo. 2007), aff’d, 330 Fed.Appx. 626
(8th Cir. 2009). Accordingly, we affirm. See 8th Cir. R. 47B.
______________________________
-2-