News & Analysis as of

Burden of Proof Income Taxes

Freeman Law

Tax Court in Brief | Scheider v. Comm’r | Deficiency for Unreported Income; Burdens of Proof

Freeman Law on

Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 | Greaves, J. | Dkt. No. 21002-16 Clark Raymond & Company, PLLC v. Comm’r, T.C. Memo. 2022-105 |...more

Freeman Law

Tax Court in Brief | Remisovsky v. Comm’r | Reasonable Cause Exception to Additions to Tax

Freeman Law on

Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Freeman Law

Tax Court in Brief | Howland v. Commissioner | Mortgage Interest Deduction in Foreclosure Sale and Accuracy-Related Penalty

Freeman Law on

Tax Litigation: The Week of June 13th, 2022, through June 17th, 2022 Phillips v. Comm’r, T.C. Memo. 2022-58 | June 13, 2022 | Lauber, J. | Dkt. No. 18553-21L Chavis v. Comm’r, 158 T.C. No. 8 | June 15, 2022 | Lauber, J. |...more

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

Rivkin Radler LLP on

Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more

Freeman Law

Accuracy-Related Penalties: The Burdens of Proof and Production

Freeman Law on

Accuracy-related penalties under section 6662 are among the most common penalties in the Tax Code.  As a result, they are often at issue in tax litigation against the IRS.  That raises the question: What are the burdens of...more

BakerHostetler

[Podcast] A Step Backwards on Alternative Apportionment - Guest Mike Semes

BakerHostetler on

In this week's episode, Mike Semes joins Matt Hunsaker in the studio to discuss alternative apportionment and an unfortunate case coming out of Maryland....more

Farrell Fritz, P.C.

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

Farrell Fritz, P.C. on

Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

McDermott Will & Emery

Court Rules that Wind Farm Did Not Provide Proof of Development Fee to Receive 1603 Cash Grant

McDermott Will & Emery on

On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party...more

Morrison & Foerster LLP

MoFo New York Tax Insights - Volume 6, Issue 10

State Tax Department Releases Draft Article 9-A Nexus Regulations Under Corporate Tax Reform - The New York State Department of Taxation and Finance has released draft amendments to the Article 9-A corporate franchise...more

Cozen O'Connor

Taxpayer Must Prove Change Of Domicile

Cozen O'Connor on

The Pennsylvania Supreme Court affirmed per curiam a decision that the burden of proving a change of domicile is on the person claiming the change. Hvizdak v. Commonwealth, 92 MAP 2012 (Pa. June 17, 2013) (per curiam), aff’g...more

10 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide