Roger J. Jones

Roger J. Jones

McDermott Will & Emery

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Ensuring Timely Filing with Private Delivery Services

Most of us are aware of the timely-mailed-timely-filed “mailbox rule” contained within the Internal Revenue Code. Most of us are probably also aware that a document mailed with a private delivery service may also qualify for...more

6/3/2014 - DHL Electronic Filing FedEx IRC IRS Mailbox Rule Tax Court UPS USPS

Focus on Tax Controversy - December 2013

In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home...more

12/5/2013 - Administrative Procedure Act False Claims Act Fraud IRS Mayo Foundation for Medical Ed Mayo Foundation v US Protective Claims SCOTUS Standard of Review State Taxes Tax Refunds Transfer Pricing Treble Damages U.S. Treasury US v Home Concrete & Supply Whistleblowers

The 3M Case: Can the IRS Overrule the Supreme Court?

3M Company’s challenge to the validity of Treas. Reg. § 1.482-1(h)(2), if successful, could result in refunds for taxpayers that previously followed the Internal Revenue Service’s regulatory guidance purporting to overrule...more

9/27/2013 - 3M Company Income Taxes IRS SCOTUS Subsidiaries Tax Refunds

CCRC Fees – A Primer on the Tax Treatment of Entrance and Monthly Fees

I. Introduction - Continuing care retirement communities (CCRCs) are professionally managed retirement communities, many of which also function as long-term skilled nursing care facilities. CCRCs offer residents...more

12/5/2012 - Continuing Care Retirement Communities Nursing Homes Retirement

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