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Income Taxes › Appeals

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

Allen Barron, Inc. on

What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

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An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Foodman CPAs & Advisors

¿Puedes Apelar Al IRS?

Foodman CPAs & Advisors on

Los contribuyentes tienen derecho a apelar al IRS. Entender cómo apelar al IRS es fundamental y los contribuyentes deben considerar contratar representación para disminuir los riesgos de litigio. Sólo los abogados, contadores...more

Foodman CPAs & Advisors

Can You Appeal The IRS?

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Taxpayers have the right to appeal the IRS. Understanding how to appeal the IRS is critical and Taxpayers ought to consider retaining representation in order to diminish the risks of litigation. Only attorneys, certified...more

Proskauer Rose LLP

UK Tax Round Up - January 2024

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Welcome to January’s edition of our UK Tax Round Up. It was announced this month that the next UK Budget will take place on 6 March 2024. HMRC also published responses on its permanent establishment consultation. In addition,...more

DarrowEverett LLP

‘As Such’: Soroban Case Puts Limited Partnerships Under Tax Scrutiny

DarrowEverett LLP on

In Soroban Capital Partners, LP v. Commissioner, the U.S. Tax Court determined that the exception to net earnings from self-employment in Section 1402(a)(13) of the Internal Revenue Code of 1986, as amended (the “Code”) ...more

McDermott Will & Emery

Remote Retailers Held Responsible for Tax Collection in Washington

McDermott Will & Emery on

If there’s a lesson to be learned from the Washington Court of Appeals’ recent holding in Orthotic Shop Inc. and S&F Corporation v. Department of Revenue, No. 39321-6-III (Jan. 23, 2024), it’s that the use of a marketplace...more

Proskauer Rose LLP

UK Tax Round Up - March 2023

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Welcome to February’s edition of our UK Tax Round Up. The month has seen interesting cases on the “entitlement” to income and the single and multiple supply tests for VAT as well as announcement of the publication date for...more

ArentFox Schiff

Court Provides Tax Relief For Those With a Second Home in New York

ArentFox Schiff on

For years taxpayers who commuted to New York for work while owning a rarely used New York vacation home or pied-a-terre have been surprised to find themselves taxed as New York State and/or City residents. This often meant...more

McDermott Will & Emery

Actual Confusion Is the Best Evidence of Confusion

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The US Court of Appeals for the Eighth Circuit reversed and vacated a district court’s preliminary injunction grant in a trademark dispute, concluding that potential confusion is insufficient to satisfy the burden of showing...more

Rosenberg Martin Greenberg LLP

Affordable Care Act Battle Rages On: Fourth Circuit Holds Individual Mandate Is a Tax in Bankruptcy

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As originally enacted, the Affordable Care Act (“ACA”) required most people to maintain health insurance. Those who did not maintain the required insurance were obligated to pay a “shared responsibility payment” (“SRP”),...more

Proskauer Rose LLP

UK Tax Round Up - November 2022

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Welcome to the November edition of the UK Tax Round Up. This month has seen the new Chancellor deliver his Autumn Statement following from the previous Chancellor’s so-called mini budget in October and the Court of Appeal’s...more

McDermott Will & Emery

Supreme Court Denies Certiorari in Whirlpool

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On November 21, 2022, the Supreme Court of the United States denied certiorari in Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9. This means that the US Court of Appeals for the...more

Freeman Law

The IRS Appeals Office

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The IRS Independent Office of Appeals (“IRS Appeals”) was established to provide an “independent” IRS function that is separate and independent from the IRS’s compliance functions that maintain responsibility for collecting...more

Proskauer Rose LLP

UK Tax Round Up

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Welcome to the August edition of the UK Tax Round Up. August turned out to be not such a quiet month on the UK tax front. We have seen several important and technical case law decisions, some of which we discuss below, and...more

Miller Canfield

The Status of the Pending Appeal in Silver v. Treasury Department

Miller Canfield on

Key Takeaways - ..The pending case, Silver v. Internal Revenue Service, will provide insight, when decided, of the view of the Court of Appeals for the District of Columbia Circuit on the scope of judicial review of...more

McDermott Will & Emery

An Update on Section 6751 Penalties

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Tax penalties are always a hot topic here. The Internal Revenue Service (IRS) has a large arsenal when it comes to grounds for asserting penalties on income tax deficiencies, ranging from the common 20% penalty under Internal...more

McDermott Will & Emery

District Court Vacates, Sets Aside IRS Reportable Transaction Notice

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The fallout from taxpayer challenges to the Internal Revenue Service’s (IRS) “reportable transaction” regime continues. On March 21, 2022, the district court in CIC Servs., LLC v. IRS ruled in favor of the taxpayer, vacating...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

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We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

Miller Canfield

Michigan Court of Appeals Upholds Taxpayer Recovery of Excess Tax Foreclosure Proceeds, Bars Multi-County Class Actions

Miller Canfield on

Key Takeaways - ..The Michigan Court of Appeals rejected an effort to allow class action recovery of excess proceeds from the sale of tax foreclosed properties. ..The Court ruled that the Michigan Supreme Court's 2020...more

Smart & Biggar

FCA upholds reconsideration decision maintaining $100M+ award against Apotex for cefaclor patent infringement

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Update: On September 28, 2021, Apotex applied to the Supreme Court of Canada for leave to appeal (Docket No. 39851).  On July 23, 2021, the Federal Court of Appeal (FCA) dismissed Apotex’s appeal of the Federal Court’s (FC)...more

McDermott Will & Emery

Nebraska District Court Holds That GIL 24-19-1 is Not Afforded Deference

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Last week, the Lancaster County District Court granted the state’s motion to dismiss in COST v. Nebraska Department of Revenue. COST brought this declaratory judgment action to invalidate GIL 24-19-1, in which the department...more

Dorsey & Whitney LLP

The Supreme Court - May 17, 2021

Dorsey & Whitney LLP on

Today, the Supreme Court of the United States issued the following four decisions: BP p.l.c. v. Mayor and City Council of Baltimore, No. 19-1189: Congress has commanded that generally, an order remanding a case back to...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Domicile:Taxpayer could have prevailed with simple affidavit

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In a recent Board of Tax Appeals Case, taxpayers contested the Department’s assessment of personal income taxes, asserting that they were not Ohio residents. See Anthony R. Joy & Robin E. Miller, (et. Al.), v. Jeffrey A....more

Holland & Knight LLP

When Is a Tax Return "Filed"?

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In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

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