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IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters.  In that case, the taxpayer stipulated that he:  (1) had Form 5471 filing obligations...more

The Art of an IRS APA Defense: Conservation Easements and Hewitt

Good tax attorneys will do whatever it ethically takes to win on behalf of their clients.  Often, this means the attorney must not only have a good understanding of the substantive provisions at play, but also relevant...more

Challenging FBAR Penalties in Federal Court: FBAR Litigation

In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more

What is an IRS Notice of Deficiency?

Ordinarily, taxpayers file their income tax returns each year with the IRS and hear nothing more. Rather, the Internal Revenue Service (“IRS”) simply processes the tax return, assesses the reported amount of tax due, and...more

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

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

[Webinar] Legal and Tax Update - July 28th, 2:00 pm CT

Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights. During this information-filled...more

Are Settlement Payments for Emotional Distress Taxable?

The proper federal tax treatment for any given settlement payment is something of an enigma. Generally, federal courts (and thus, the IRS) respect the terms of a settlement agreement if the terms are clear and the parties...more

The King of Pop, Michael Jackson’s, Estate Wins Big at Tax Court

Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more

Listed Transaction Penalty Upheld by Federal Circuit Court

Tax professionals are intimately familiar with certain reporting requirements under the Internal Revenue Code. Indeed, a failure to properly and timely report a position on a return where it is otherwise required may result...more

Clarifying the Contours of “Reasonable Compensation”

The law has always favored the term “reasonable.”  For example, the law affords protection against a negligence lawsuit if a person can demonstrate he or she acted as a reasonable person would have under similar...more

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