Earlier this year, the United States District Court for the Middle District of Louisiana upheld the Internal Revenue Service’s disallowance of $1 billion of deductions claimed by Dow Chemical in relation to two transactions...more
4/4/2013 - Dow Chemical IRS Partnerships Tax Deductions Tax Fraud TEFRA
The year 2012 was quite an interesting one for tax controversy. Whereas 2011 brought a win for the Treasury on deference issues in Mayo Foundation for Medical Ed. v. United States, 131 S. Ct. 704 (2011), 2012 was the year...more
1/16/2013 - Administrative Procedure Act Dominion Resources FICA H&M Hewlett-Packard IRS Mayo Foundation for Medical Ed Net Investment Income PepsiCo Quality Stores SCOTUS Severance Pay
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