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Internal Revenue Service Joint and Several Liability

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Freeman Law

Tax Court in Brief | Soler v. Commissioner | Innocent Spouse Relief Under 6015(b) and (f) Denied

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Tax Litigation: The Week of July 18th, 2022, through July 22nd, 2022 Pettennude v. Comm’r, T.C. Memo. 2022-79 | July 18, 2022 | Buch, J. | Dkt. No. 636-21L Gonzalez v. Comm’r, T.C. Summary Opinion 2022-13 | July 18, 2022 |...more

Freeman Law

Tax Court in Brief | Pocock v. Commissioner | Equitable Innocent Spouse Relief Under 6015(f)

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Tax Litigation: The Week of June 6th, 2022, through June 10th, 2022 Musselwhite v. Commissioner, T.C. Memo. 2022-57 | June 8, 2022 | Ashford, J.| Dkt. No. 14380-16 Spencer v Commissioner, T.C. Memo. 2022-8 | June 7, 2022 |...more

Freeman Law

Tax Court in Brief | Podlucky v. Commissioner | $34M Jewelry in a Secret Room, Constructive Receipt, Innocent Spouse, and Putative...

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Tax Litigation: The Week of May 2nd, 2022, through May 6th, 2022 DelPonte v. Comm’r, 158 T.C. No. 7 | May 5, 2022 | Holmes, J. | Dkt. Nos. 1144-05, 1334-06, 20679-09, 20680-09, 20681-09 Mighty v. Comm’r, TC Memo. 2022-44|...more

Freeman Law

Actions (and Inactions) Matter with Innocent Spouse Relief—Jones v. Commissioner

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A taxpayer may request innocent spouse relief from the Internal Revenue Service (“IRS”) in the form of equitable relief—I.R.C. § 6015(f). Among its threshold conditions, Section 6015(f) generally requires an evaluation of...more

Freeman Law

Tax Court Grants Innocent Spouse Relief

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In the recent case of Todisco v. Commissioner of Internal Revenue, the Tax Court granted innocent spouse relief to the taxpayer, finding that it would be inequitable to hold her liable for the taxes at issue.  As a result,...more

Freeman Law

The Tax Court in Brief - September 2021 #3

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Tax Court Litigation: The Week of September 13 – September 17, 2021 - Donna M. Sutherland v. Comm’r, No. 3634-18, T.C. Memo 2021-110 | September 16, 2021 | Lauber | Dkt. No. 3634-18 - Short Summary: This is an...more

Freeman Law

What is reasonable compensation for employees of an I.R.C. § 501(c)(3)? (Part 1)

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One of the most important decisions a board determines is what constitutes reasonable compensation. The rules for this determination are robust and so are the taxes imposed for violations of the Internal Revenue Code and the...more

Freeman Law

The Tax Court in Brief - February 2021 #4

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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. The Week of February 22 – February 26, 2021 - Llanos v. Commissioner...more

Freeman Law

The Tax Court in Brief

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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. The Week of October 31 – November 6, 2020 - Glade Creek Partners,...more

McDermott Will & Emery

Tax Blog: New Questions and Answers for Section 965

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The IRS has released new informal guidance (“Questions and Answers”) regarding section 965, containing information on making successive installment payments, filing transfer agreements as a result of certain acceleration or...more

Proskauer Rose LLP

Partnership-Level Tax Under New Audit Rules

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The Bipartisan Budget Act of 2015, signed into law on November 2, 2015, has significantly changed the partnership tax audit rules, effective for tax years beginning after December 31, 2017. Under the current partnership...more

Blank Rome LLP

Court’s Ruling Holding Corporate Officer Responsible for Trust Fund Recovery Penalty Illustrates Risk of Personal Liability for...

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A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more

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