The U.S. Tax Court recently decided that the one-per-year IRA rollover limitation in 26 U.S.C. § 408(d)(3)(B) applies in the aggregate to all of the taxpayer’s IRA accounts rather than separately to each of a taxpayer’s IRA...more
Last year, Florida Governor Rick Scott signed the Florida Revised Limited Liability Company Act (the New Act) into law. The New Act, which is codified in new Chapter 605 of the Florida Statutes, is a complete rewrite of the...more
On January 10, 2014, the Supreme Court granted review of an Eleventh Circuit case addressing the circumstances under which a taxpayer can obtain an evidentiary hearing in challenging a summons issued by the Internal Revenue...more
In United States v. Woods, No. 12-562, 2013 U.S. LEXIS 8776 (December 3, 2013), the U.S. Supreme Court upheld the imposition of the 40 percent gross valuation misstatement penalty set forth in 26 U.S.C. § 6662 where the...more