News & Analysis as of

Deficiency Notices

IRS Schools Taxpayers On Duty Of Consistency

by Charles (Chuck) Rubin on

Shirley died in October 1997. The estate filed an estate tax return and paid the tax indicated. The IRS subsequently audited Shirley’s estate and issued a notice of deficiency. After Tax Court proceedings, the court issued a...more

FERC Staff Questions Wind Farms on Calculation of PURPA’s One-Mile Rule

On June 9, 2017, Beaver Creek Wind II, LLC and Beaver Creek Wind III, LLC (together, “Beaver Creek”) responded to a deficiency letter from the Federal Energy Regulatory Commission (FERC or the “Commission”) staff seeking...more

Section 1111(b) Election Not Available When Collateral Is Sold Post Petition

by Dechert LLP on

The facts in Salamon are straightforward. Salamon (“Buyer”) purchased real property from Behrend (“Seller”) that was already subject to two liens (the “Preexisting Debt”). Instead of paying cash at closing, the Buyer executed...more

Michael Jackson Estate Tax Case Moving Forward

by Charles (Chuck) Rubin on

Most estate tax practitioners will tell you estate tax it is all about valuation when assets are other than cash and marketable securities. The estate tax case of the Michael Jackson estate is an ideal demonstration. Tax...more

Real Property & Title Insurance Update: Week Ending January 27, 2017

by Carlton Fields on

REAL PROPERTY UPDATE - Foreclosure/Lis Pendens: a proper reading of Florida Statute section 48.23(1)(d) is that “when a foreclosure action is prosecuted to a judicial sale, that sale discharges all liens, whether...more

Burden of Proof Issues in Gift Tax Matter

by Charles (Chuck) Rubin on

A recent case illustrates 3 important burden of proof issues. The general facts of the case involved a merger of a company owned by parents with a company owned by children. The gift tax issue involved the relative value...more

What Do All These IRS Collection Letters Mean?

by McNair Law Firm, P.A. on

When someone owes the IRS taxes, as a result of not paying the tax shown as due on a tax return or where the IRS audits and imposes additional taxes owed, the IRS will “assess” this tax liability, and with penalties and...more

Burr Alert: Dead Letter Office: The Final Repose of the Georgia Confirmation Statute?

by Burr & Forman on

In what might be viewed as the last nail in the coffin for Georgia’s confirmation statute, the Georgia Supreme Court’s recent opinion in PNC Bank, National Association v. Smith affirms that a lender may contract around the...more

Obtaining Relief from Penalties Related to IRS Form 1098-T Filing Deficiencies

It has been reported that many colleges and universities have received IRS Notices assessing significant penalties for failing to provide accurate or complete information on IRS Forms 1098-T. Going forward, colleges and...more

Stamps.com Date is Not Proof of Mailing Date

by Charles (Chuck) Rubin on

A taxpayer who receives a notice of deficiency (also known as a 90 day letter) has 90 days to file a petition to challenge the deficiency in Tax Court. This deadline is important, since this is the only method of challenging...more

Is Your Tax Return Being Audited? Know What To Do!

For most people, when their income tax returns are being selected for examination by the IRS, their first reaction is panic. No need to worry. In such a situation, you should know what to do next, what to expect next, and...more

Revisions To Mortgage Foreclosure Procedures In Florida

HB 87, a controversial foreclosure bill that passed the Legislature, was signed into law by Governor Rick Scott on June 7, 2013 to become Chapter 2013-137 of Florida laws....more

MoFo New York Tax Insights - Volume 4, Issue 3 - March 2013

by Morrison & Foerster LLP on

In This Issue: Court of Appeals Hears Oral Argument in Amazon Sales Tax Appeal; Tribunal Affirms There Is No Right to a Hearing Without a Notice of Deficiency or Refund Denial; Department Rules that Real Estate-Related...more

When Is A Notice Addressed To A Person Outside Of The United States?

by Charles (Chuck) Rubin on

Seems like a simple question, but is it? Is a notice addressed to a person outside of the U.S. if at the time of mailing the person is physically in the U.S., even though they reside outside of the U.S.? What about if it was...more

Life Sciences Company Obtains Dismissal of Shareholder Class Action

The US District Court for the Middle District of Tennessee recently granted BioMimetic Therapeutics Inc.’s motion to dismiss the class action against it, and denied plaintiffs leave to amend their complaint. Shareholders...more

Revised NASDAQ Rules Relating to Public Disclosure by Listed Issuers Following Receipt of Notification of Non-compliance with...

by Dechert LLP on

The U.S. Securities and Exchange Commission (“SEC” or the “Commission”) has approved a NASDAQ proposed rule change that revises disclosure requirements following a listed issuer’s receipt of notification from NASDAQ that the...more

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