Mary McNulty

Mary McNulty

Thompson & Knight LLP

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Latest Publications


Fifth Circuit Holds that Loss on Abandoned Securities is Ordinary Loss

Wednesday, the Fifth Circuit issued its decision in Pilgrim’s Pride and held that a loss on abandoned securities is ordinary. The Fifth Circuit rejected the IRS’s argument that Section 1234A and Section 165(g) apply to treat...more

2/27/2015 - IRS Ordinary Loss Securities Tax Court

GAO Issues Final Report with Recommendations to Improve Large Partnership Audits

The Government Accountability Office (“GAO”) recently issued its final report with recommendations to improve the efficiency and effectiveness of large partnership audits, a copy of which is available here. The GAO issued...more

10/8/2014 - Audits Final Guidance GAO IRS Partnerships TEFRA

GAO Issues Preliminary Report on Challenges in Auditing Large Partnerships

The Government Accountability Office (“GAO”) recently issued a preliminary report on the challenges in auditing large partnership returns, a copy of which is available here. The GAO issued an interim report earlier this year...more

9/26/2014 - Audits GAO IRS Partnerships

Tax Court Decisions: Briefing, Opinion, and Decision, Rule 155, and Supplemental Proceedings

- Briefing - Opinion - Post-Trial Motions - Claims For Litigation And Administrative Costs Under Code § 7430 (Other Than Code § 7430(F)(2)) - Decision - Appeals From Tax Court -...more

8/8/2014 - Tax Court

Mary Mcnulty Quoted On Court Of Federal Claims Decision In Interest Netting Case

Mary McNulty was quoted in a Tax Notes Today article (subscription required) on the Court of Federal Claims decision in Wells Fargo. In Wells Fargo, the Court of Federal Claims found that a taxpayer may net underpayment...more

7/22/2014 - Acquisitions Overpayment Wells Fargo

Supreme Court Provides Standard for Evidentiary Hearing in IRS Summons Enforcement Proceeding

On June 19, 2014, the Supreme Court unanimously ruled that taxpayers have a right to an evidentiary hearing in an IRS summons enforcement action when the taxpayer “offers some credible evidence supporting his charge” of...more

7/3/2014 - Bad Faith Corporate Taxes Document Requests Enforcement Enforcement Actions IRS Partnerships Request For Information SCOTUS Summons US v Clarke

Court of Federal Claims: Merged Corporations are the Same Taxpayer for Interest Netting

In Wells Fargo, the Court of Federal Claims held that a taxpayer may net underpayment balances and overpayment balances among merged entities under Section 6621(d). Section 6621(d) provides that, to the extent the “same...more

7/3/2014 - Banks Corporate Taxes Mergers Tax Liability Wells Fargo

Supreme Court hears Oral Arguments in Summons Enforcement Case

The IRS may summon any person to produce books, papers, records or any data that may be relevant in an exam. If a summoned party refuses to comply, the IRS must petition a district court to enforce the summons. The summoned...more

5/29/2014 - Enforcement Actions Evidentiary Hearings Information Document Requests IRS Summons

The New IDR Process: How to Prepare Your Boss

In this presentation: - New IDR Process - Issuance of IDRs - IDR Response Best Practices by Taxpayers - IDR Extensions - New IDR Enforcement Process - Countdown to Summons - Summons Enforcement Proceeding -...more

5/19/2014 - Delinquency Status Enforcement Actions Evidentiary Hearings Federal Rules of Civil Procedure Information Document Requests IRS Summons

Tax Court finds Roth IRAs were Pass-thru Partners

The complex TEFRA procedures for partnership audits and litigation require the IRS to notify partners of the beginning of a partnership audit. The IRS is not required to give notice to indirect partners, who own their...more

5/19/2014 - IRS Pass-Through Entities Super Roth IRA TEFRA

Employers Who Paid FICA Taxes on Severance Pay in 2010 Should Consider Filing Protective Refund Claims by April 15, 2014

The Supreme Court has yet to issue a ruling in the Quality Stores case to decide whether supplemental unemployment compensation benefit payments—a term which includes severance pay—should be subject to FICA taxes. We have...more

3/5/2014 - FICA Taxes Form 941 Quality Stores severence agreements Tax Refunds Unemployment Benefits

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