The United States Supreme Court has picked up the pace this week, already issuing eight regular opinions and four opinions relating to orders as of today. We discuss the tax-related items here.
In Rodriguez v. FDIC, the...more
2/27/2020
/ Administrative Procedure Act ,
Affiliated-Business Arrangements ,
Appeals ,
Bob Richards Rule ,
Consolidated Tax Returns ,
Federal Common Law ,
Federal v State Law Application ,
Internal Revenue Code (IRC) ,
IRS ,
Jurisdiction ,
Kisor v Wilkie ,
Lack of Authority ,
Parent Corporation ,
Petition for Writ of Certiorari ,
Remand ,
Rodriguez v Federal Deposit Insurance Corp. ,
SCOTUS ,
State Law Claims ,
Tax Allocation Agreements ,
Tax Reform ,
Tax Refunds ,
Unconstitutional Condition ,
Vacated
In a highly-anticipated Technical Advice Memorandum (TAM) dated March 23, 2017 and released on July 21, 2017, the Internal Revenue Service (IRS) ruled that two taxpayers who had invested in a Limited Liability Company that...more
Two petitions for certiorari are pending before the Supreme Court of the United States, asking the Court to resolve the question of whether a tax return filed after an assessment by the Internal Revenue Service (IRS) is a...more
On September 19, 2014, the U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds based on foreign tax...more
Most of us are aware of the timely-mailed-timely-filed “mailbox rule” contained within the Internal Revenue Code. Most of us are probably also aware that a document mailed with a private delivery service may also qualify for...more