Brian Harris

Brian Harris

Akerman LLP

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IRS Changes Position on Non-Taxable IRA Rollover Contributions

The U.S. Tax Court recently decided that the one-per-year IRA rollover limitation in 26 U.S.C. § 408(d)(3)(B) applies in the aggregate to all of the taxpayer’s IRA accounts rather than separately to each of a taxpayer’s IRA...more

4/23/2014 - IRA IRA Rollovers Non-Taxable Income

Supreme Court to Decide When Taxpayers Can Obtain an Evidentiary Hearing in a Summons Enforcement Action

On January 10, 2014, the Supreme Court granted review of an Eleventh Circuit case addressing the circumstances under which a taxpayer can obtain an evidentiary hearing in challenging a summons issued by the Internal Revenue...more

1/22/2014 - Evidentiary Hearings Fifth Amendment Income Taxes IRS SCOTUS Summons

Supreme Court Upholds a 40 Percent Valuation Misstatement Penalty Based on a Misrepresentation of Basis

In United States v. Woods, No. 12-562, 2013 U.S. LEXIS 8776 (December 3, 2013), the U.S. Supreme Court upheld the imposition of the 40 percent gross valuation misstatement penalty set forth in 26 U.S.C. § 6662 where the...more

12/23/2013 - Misrepresentation Property Valuation SCOTUS Tax Basis United States v Woods Valuation

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