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II-31- The Changing 9 to 5 From 1980 to Today
Accuracy-related penalties under section 6662 are among the most common penalties in the Tax Code. As a result, they are often at issue in tax litigation against the IRS. That raises the question: What are the burdens of...more
The United States Court of Appeals for the Tenth Circuit’s recent opinion in Standing Akimbo, LLC v. United States, No. 19-1049 (10th Cir. April 7, 2020), reminds us of the Internal Revenue Service’s (IRS) ability to obtain...more
Generally, for a tax qualified retirement plan to be adopted, the plan document must be signed and dated by the sponsoring employer and retained. However, in Val Lanes Recreation Center Corp. v. Commissioner of Internal...more
On June 20, 2019, the United States Court of Federal Claims published its long-awaited opinion in California Ridge Wind Energy, LLC v. United States, No. 14-250 C. The opinion addressed how taxpayers engaging in related party...more
The United States Court of Federal Claims recently released two anticipated opinions, Bishop Hill Energy, LLC v. United States and California Ridge Wind Energy, LLC v. United States, which were issued under seal on January 7,...more
Campus Real Estate, Property Management, Tax Credits The 15th Annual Higher Education Real Estate Lawyers conference was held in San Francisco, where attendees listened to and learned from both in-house and outside counsel at...more
Under the new Section 7345 of the Internal Revenue Code coming into effect in January 2018, Congress has given the IRS the power to “certify” the names of delinquent taxpayers to the State Department for purposes of denying...more
On November 2, 2015, President Barack Obama signed into law the Bipartisan Budget Act of 2015 (the Act). The Act overhauls the partnership audit and litigation rules in the Internal Revenue Code, repealing both the provisions...more