David Rosen

David Rosen

Akerman LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

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

Florida’s New LLC Act from the Lender’s Perspective

Last year, Florida Governor Rick Scott signed the Florida Revised Limited Liability Company Act (the New Act) into law. The New Act, which is codified in new Chapter 605 of the Florida Statutes, is a complete rewrite of the...more

2/6/2014 - Corporate Management Creditors' Rights Lenders Limited Liability Companies LLC Third-Party

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

4 Results
|
View per page
Page: of 1