Massoud Fanaieyan & Ziba Fanaieyan v. Commissioner

2019 T.C. Memo. 125
CourtUnited States Tax Court
DecidedSeptember 19, 2019
Docket20618-17
StatusUnpublished

This text of 2019 T.C. Memo. 125 (Massoud Fanaieyan & Ziba Fanaieyan v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Massoud Fanaieyan & Ziba Fanaieyan v. Commissioner, 2019 T.C. Memo. 125 (tax 2019).

Opinion

T.C. Memo. 2019-125

UNITED STATES TAX COURT

MASSOUD FANAIEYAN AND ZIBA FANAIEYAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 20618-17. Filed September 19, 2019.

Massoud Fanaieyan and Ziba Fanaieyan, pro sese.

Andrew R. Moore, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

PUGH, Judge: In a notice of deficiency dated August 1, 2017, respondent

determined a $15,270 deficiency in petitioners’ Federal income tax and a $3,054 -2-

[*2] penalty under section 6662(a) for 2015.1 The issue for decision is whether

petitioners qualify for the premium assistance tax credit (PTC) under section 36B.2

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. The stipulated

facts are incorporated in our findings by this reference. Petitioners resided in

California when they timely filed their petition. In 2015 Mr. Fanaieyan was

retired and owned rental properties, and his wife worked as a hairstylist. Before

retirement he worked as a manager for a financial institution.

Petitioners received health insurance coverage through the Covered

California Health Insurance Marketplace created under the Patient Protection and

Affordable Care Act (ACA), Pub. L. No. 111-148, 124 Stat. 119 (2010), from

March through December 2015, and their two children received coverage from

March through September 2015. Petitioners received the benefit of the $15,267 in

advance payments of the PTC (APTC) for their health insurance.

1 Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. All monetary amounts are rounded to the nearest dollar. 2 Respondent has conceded that petitioners are not liable for the $3,054 sec. 6662(a) penalty. -3-

[*3] Petitioners timely filed a joint Form 1040, U.S. Individual Income Tax

Return, for 2015. On their 2015 Form 1040 they reported adjusted gross income

of $100,767 and claimed four exemptions (for themselves and their children) but

failed to report the APTCs paid on their family’s behalf or to reconcile that

amount with their allowable PTC on Form 8962, Premium Tax Credit (PTC).

Respondent determined that petitioners were not entitled to the PTC and

therefore increased their tax liability by the amount of the APTCs. After this case

was continued from a previous trial calendar, petitioners provided to respondent a

Form 1040X, Amended U.S. Individual Income Tax Return, for 2015. An

attached Schedule C, Profit or Loss From Business, reported that Mr. Fanaieyan

operated a publishing business that used the cash receipts and disbursements

method of accounting, realized income of $731, and incurred expenses of $6,157

for a net loss of $5,426. That loss reduced petitioners’ adjusted gross income

reported on the Form 1040X to $95,341.

The publishing business consisted of Mr. Fanaieyan’s efforts beginning no

later than 2012 to publish and promote a book written by his sister. She wrote the

book--a fictional account of challenges faced by a Baha’i student in Iran--to

publicize the plight of a persecuted religious minority in Iran but was not able to

publish it there. Mr. Fanaieyan wanted to support his sister’s efforts to bring -4-

[*4] attention to the issue and hoped that the book would generate enough revenue

to cover publishing expenses and provide some income for his sister in Iran. His

efforts to promote his sister’s book were spread over several years but did not take

up most of his time and had ceased by 2015. A schedule of income and expenses

prepared by Mr. Fanaieyan shows (1) expenses for 2012 and 2013 for publishing

the book and shipping it to various readers, (2) no expenses for 2014, and (3) a

single expense of $1,500 for 2015 labeled “advance to the author”. The schedule

also lists income from a few sales of the book in 2012 and 2013, but no sales in

2014 or 2015.

OPINION

I. Burden of Proof

Ordinarily, the taxpayer bears the burden of proving that the

Commissioner’s determinations are erroneous. Rule 142(a); Welch v. Helvering,

290 U.S. 111, 115 (1933). In particular, taxpayers bear the burden of proving

entitlement to any deductions claimed. INDOPCO, Inc. v. Commissioner, 503

U.S. 79, 84 (1992); New Colonial Ice Co. v. Helvering, 292 U.S. 435, 440 (1934).

The burden of proof shifts to the Commissioner under section 7491(a) when a

taxpayer comes forth with credible evidence with respect to any factual issue

relevant to ascertaining the taxpayer’s liability. See Rule 142(a)(2). Petitioners do -5-

[*5] not contend, nor does the evidence establish, that the burden shifts to

respondent under section 7491(a) as to any issue of fact.

II. Premium Tax Credit

Section 36B provides for a PTC to subsidize the cost of health insurance

purchased through a Health Insurance Marketplace by taxpayers meeting certain

statutory requirements. See sec. 1.36B-2(a), Income Tax Regs. That section was

created by ACA secs. 1401(a) and 10105(a)-(c), 124 Stat. at 213, 906, and the

Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, sec.

1001(a)(1), 124 Stat. at 1030, together commonly referred to as the Affordable

Care Act. See McGuire v. Commissioner, 149 T.C. 254, 259 (2017). The PTC is

available to households with incomes between 100% and 400% of the Federal

poverty line. Sec. 36B(c)(1)(A). Eligible taxpayers may claim the PTC for health

insurance covering dependents, sec. 36B(b)(2)(A), and dependents may not claim

the credit on their own returns, sec. 36B(c)(1)(D). APTCs are made directly to an

insurer during the taxable year. ACA sec. 1412(c)(2)(A), 124 Stat. at 232

(codified at 42 U.S.C. sec. 18082 (2012)).

APTCs made on behalf of a taxpayer or members of the taxpayer’s

household, including dependent children, must be reported on the taxpayer’s Form

1040. If the amount of the APTCs exceeds the PTC to which the taxpayer is -6-

[*6] entitled, the excess increases the tax owed by the taxpayer and reduces any

refund otherwise payable to the taxpayer. Sec. 36B(f)(2); sec. 1.36B-4, Income

Tax Regs.; sec. 1.36B-4T(a)(1)(ii)(A), Temporary Income Tax Regs., 79 Fed. Reg.

43628 (July 28, 2014) (“A taxpayer must reconcile all advance credit payments for

coverage of any member of the taxpayer’s family.”); see McGuire v.

Commissioner, 149 T.C. at 261.

Petitioners do not dispute the facts surrounding the APTCs made on their

behalf; they argue only that they should be able to deduct losses arising from the

publishing business claimed on their 2015 Form 1040X, reducing their income by

that amount. The Federal poverty line for 2015 for a family of four residing in

California was $24,250 and 400% of the Federal poverty line was $97,000. See

80 Fed. Reg. 3236-3237 (Jan. 22, 2015).

If petitioners are entitled to a deduction for the publishing business losses

their household income (defined as their adjusted gross income with modifications

not relevant here, sec. 36B(d)(2); sec. 1.36B-1(e)(2), Income Tax Regs.) would

fall below 400% of the applicable Federal poverty line for their family, and they

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Related

Welch v. Helvering
290 U.S. 111 (Supreme Court, 1933)
New Colonial Ice Co. v. Helvering
292 U.S. 435 (Supreme Court, 1934)
Indopco, Inc. v. Commissioner
503 U.S. 79 (Supreme Court, 1992)
Hylton v. Comm'r
2016 T.C. Memo. 234 (U.S. Tax Court, 2016)
Warden v. Commissioner
1995 T.C. Memo. 176 (U.S. Tax Court, 1995)

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