Income Taxes, Tax Litigation

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

McDermott Will & Emery on 5/2/2024

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Unrealized Income Under Scrutiny: Will SCOTUS Unleash Chaos on the US Tax Code?

Kohrman Jackson & Krantz LLP on 2/23/2024

In December 2023, the Supreme Court considered the fundamental question: “How is income defined?” Moore v. United States centered on the question of taxation of unrealized income. Unrealized income is defined as a gain that...more

Tax Court Confirms Taxpayer’s Right to Dismiss Their Own Lawsuit

Gray Reed on 9/21/2023

An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.” ...more

Buehler Doesn’t Get a Day Off from Double Taxation

McDermott Will & Emery on 5/12/2023

The California Office of Tax Appeals (OTA) recently held that a California resident’s income tax paid to Massachusetts from the sale of his membership interest in a limited liability company (LLC) doing business in...more

PA Supreme Court Interprets “Costs of Performance” Statute and Determines Attorney General’s Office May Take Independent Positions...

McNees Wallace & Nurick LLC on 3/27/2023

In a long-awaited decision, the Pennsylvania Supreme Court recently held in Synthes USA HQ, Inc. v. Commonwealth, 11 MAP 2021, that service providers were required to apportion receipts based on the location where the...more

Weekly IRS Roundup March 13 – March 17, 2023

McDermott Will & Emery on 3/21/2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more

Review of 2022 Arizona Tax Highlights

Lewis Roca on 2/22/2023

ARIZONA TO IMPLEMENT 2.5% FLAT TAX AHEAD OF SCHEDULE - Governor Doug Ducey announced that Arizona will implement its new 2.5% flat income tax rate on January 1, 2023, a full year ahead of schedule. According to Gov. Ducey,...more

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

Buckingham, Doolittle & Burroughs, LLC on 2/17/2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

Whose Income Producing Activity Is It Anyway?

Blank Rome LLP on 1/23/2023

Both states and taxpayers have struggled with how to correctly source service receipts for apportionment purposes. The myriad of state sourcing provisions certainly do not add any clarity to the issue. Muddying the waters...more

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

Freeman Law on 12/5/2022

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

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

Freeman Law on 11/7/2022

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

The Taxpayer Bill of Rights

Freeman Law on 9/27/2022

The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more

The Turbulent Ride for Washington's New Capital Gains Tax May Have Come to a Screeching Halt

Foster Garvey PC on 3/3/2022

As previously reported on May 7, June 17 and November 4 of last year, two lawsuits were filed in Douglas County Superior Court in Washington, seeking a declaration that the state’s new capital gains tax is unconstitutional....more

Crypto Tax Lawyers – 5 Things to Consider Before Hiring

Oberheiden P.C. on 2/7/2022

The IRS, Taxpayers, and Cryptocurrencies or virtual currencies - The Internal Revenue Service (“IRS”) issued its first guidance on cryptocurrencies— “virtual currencies''—in 2014, taking the position that crypto...more

[Podcast] One Simple Trick for Cutting Your State Taxes in Half

BakerHostetler on 10/14/2021

Texas taxes retailers and wholesalers at half the rate of other taxpayers. Matt Hunsaker breaks down the recent Xerox franchise tax case and what it may mean for leasing companies trying to qualify as retailers or...more

[Podcast] Statues, Texas Apportionment (Sirius XM), and Maryland Digital Ad Tax Regs

BakerHostetler on 10/13/2021

Matt Hunsaker breaks down the latest state tax news including a discussion of tax arguments in a controversial civil war era statue removal case, the Texas Supreme Court's decision to hear Sirius XM's apportionment case, and...more

District Court Broadly Interprets Informal Claim Doctrine

McDermott Will & Emery on 10/6/2021

Internal Revenue Code (Code) section 7803(a)(3)(C) provides that taxpayers have “the right to pay no more than the correct amount of tax.” However, there are two relevant considerations to this “right.” First, the Internal...more

[Webinar] Freeman Law’s Tax Court Examination Course: An Introduction to the Tax Court: Jurisdiction, Procedure, and Overview -...

Freeman Law on 8/19/2021

This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more

Income Taxes › Tax Litigation