Thomas Cullinan

Thomas Cullinan

Sutherland Asbill & Brennan LLP

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Legal Alert: U.S. Supreme Court Resolves Circuit Split: Holds Valuation Misstatement Penalty Applies in Partnership Tax Shelter...

On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more

12/20/2013 - Asset Valuations Income Taxes IRS Jurisdiction Material Misstatements Partnerships Penalties SCOTUS Tax Shelters TEFRA Underpayment

Legal Alert: A Trend Emerging? District Court Disallows $1 Billion of Deductions

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

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