Law School Toolbox Podcast Episode 332: Listen and Learn -- Removal (Civ Pro)
Bar Exam Toolbox Podcast Episode 163: Listen and Learn -- Removal (Civ Pro)
Bar Exam Toolbox Podcast Episode 145: Listen and Learn -- Permissive Joinder and Required Joinder
Law School Toolbox Podcast Episode 263: Listen and Learn -- Subject Matter Jurisdiction
Bar Exam Toolbox Podcast Episode 92: Listen and Learn -- Subject Matter Jurisdiction
Bar Exam Toolbox Podcast Episode 72: Tackling a California Bar Exam Essay: Civil Procedure
The U.S. Supreme Court rules that the IRS does not need to provide notice to innocent bank account holders when the summonses are issued in aid of collection of a delinquent taxpayer’s tax assessment. ...more
Third-party summonses. Taxpayers, individuals, and companies, alike, should be aware of the Internal Revenue Service’s (“IRS”) power to issue third-party summonses. Even more, interested parties should note that only parties...more
The Supreme Court’s recent decision in CIC Services, LLC v. Internal Revenue Service may have significantly expanded taxpayers’ ability to obtain immediate injunctive relief against onerous tax reporting requirement....more
In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more
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
The recent case of In re Bowman, Case No. 20-11512, Section A (Bankr. E.D. La., July 12, 2021) addresses an interesting intersection of tax and bankruptcy law. Specifically, it looks at the issue of whether bankruptcy courts...more
The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations. Key Points: ..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS...more
The U.S. Supreme Court recently rendered a unanimous opinion holding that the Anti-Injunction Act (AIA) did not block a lawsuit brought by CIC Services against the Internal Revenue Service (IRS), delivering an important...more
In CIC Services, LLC v. Internal Revenue Service, a unanimous US Supreme Court allowed CIC, a tax advisor, to proceed with a pre-enforcement challenge to the Internal Revenue Service’s (IRS) “reportable transaction” regime....more
On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more
Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action....more
The Supreme Court held that a company may bring a pre-enforcement challenge under the Administrative Procedure Act ("APA") to an IRS reporting requirement backed by a tax penalty. On May 17, 2021, the U.S. Supreme Court...more
Federal tax cases against the IRS can be difficult. Even procedurally so. Under the pay-first, litigate-later rule, taxpayers are generally required, prior to filing suit against the United States: (1) to full pay the...more
This week, we look at one decision navigating the complicated jurisprudence governing review of remand orders (which one might think would be unreviewable), and another addressing the available penalties when taxpayers fail...more
October 2019 Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split-Interest Charitable Trusts - The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs,...more
This week saw two items of note in the regulation of digital assets and both came out of the state of New York. The Return of the Empire State - A New York State Supreme Court ruled that it has personal and subject...more
Key Cases - Covert Surveillance Due to Religious Identity is Actionable - Government surveillance of individuals due to their religious identity is actionable under federal law. In Fazaga v. Federal Bureau of...more
When was the last time your organization reviewed your insurance policies? Not all policies are equal. Many religious organizations are underinsured. Most should have general liability, property, professional liability,...more
In This Presentation: - Davidson v. Henkel Corp. - The Parties - NQ Plan - The Plan’s Tax Clauses - Davidson’s Pre-Retirement Counseling - 2011 Compliance Review and Letter - Henkel’s Tax...more