Thomas Cullinan

Thomas Cullinan

Sutherland Asbill & Brennan LLP

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Legal Alert: The 2013 Tax Litigation Year in Review: Important Events

As we look forward to 2014, we take a look back at the top 10 important tax controversy issues making the news in 2013 that may have continuing importance in the future....more

1/31/2014 - Banks IRS SCOTUS United States v Woods UTPs Valuation Wells Fargo

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: The 2012 Tax Litigation Year in Review: Important Events

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 Taxes H&M Hewlett-Packard IRS Mayo Foundation for Medical Ed Net Investment Income PepsiCo Quality Stores SCOTUS Severance Pay

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