Discovery, Income Taxes

UK Tax Round Up - September 2021

Proskauer Rose LLP on 9/30/2021

In Fashion on the Block Limited v HMRC, the First-tier Tribunal (FTT) has allowed the taxpayer’s appeal against HMRC’s decision not to allow the taxpayer company to issue seed enterprise investment scheme (SEIS) certificates...more

Executor Seeks Refund of Fiduciary Income Taxes, and The Application of Iqbal/Twombly to Defensive Pleadings in Tax Cases

Freeman Law on 9/3/2021

The executor of the Estate of Tamir Sapir is seeking a refund of more than $25 million of fiduciary income tax alleged to have been overpaid to the Internal Revenue Service (“IRS”). While the refund suit is currently teed up...more

New Mexico Court of Appeals Upholds Refund Claim Dismissal for Taxpayer’s Violation of Discovery Order

Pillsbury - SeeSalt Blog on 3/9/2020

The New Mexico Court of Appeals decided a case illustrating the heavy risks of failing to comply with a court’s order. Specifically, the Court of Appeals upheld the District Court’s full dismissal of a taxpayer’s refund...more

Hundreds of Objections Later, Indiana Tax Court Awards Attorney’s Fees in Income Tax Appeal; Court Dismisses Untimely Assessment...

Faegre Drinker Biddle & Reath LLP on 6/20/2016

In two opinions issued March 7, 2016, the Indiana Tax Court dealt another hand in the ongoing (and seemingly never-ending) discovery dispute between Gambler Nick Popovich and the Department of Revenue, awarding Popovich...more

Missing Transmittal Envelope Was Not The Intentional Spoliation Of Evidence Justifying Indiana Tax Court’s Dismissal Of Income Tax...

Faegre Drinker Biddle & Reath LLP on 10/2/2014

An Indiana gambler lost another hand in the latest ruling by the Tax Court on his continuing discovery disputes with the Indiana Department of Revenue. On September 18th the Court denied Nick Popovich’s motion for default...more

The Gambler Breaks Even: Tax Court Orders Indiana Department Of Revenue To Answer Discovery Requests But Denies Taxpayer’s Second...

Faegre Drinker Biddle & Reath LLP on 7/15/2014

The Tax Court does not often address discovery issues in published decisions and orders. In this case, Popovich v. Indiana Department of State Revenue, Cause No. 49T10-1010-TA-53 (April 24, 2014 and June 4, 2014), the Court...more

District Court Accords Work Product Protection to Taxpayer Documents Prepared during a Transaction’s Planning Stages

McDermott Will & Emery on 12/9/2013

The U.S. District Court for the District of Delaware recently interpreted the work product privilege in a manner favorable to taxpayers, ruling that documents can be prepared “in anticipation of litigation” even if created...more

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