News & Analysis as of September 22, 2024

Tax Litigation

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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 -

[Event] Tax Symposium 2024 - May 14th - 15th, Chicago, IL

McDermott Will & Emery on 5/2/2024

Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more

Tax Court Confirms Taxpayer’s Right to Dismiss Their Own Lawsuit

Gray Reed on 9/21/2023

An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.” ...more

Weekly IRS Roundup March 13 – March 17, 2023

McDermott Will & Emery on 3/21/2023

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more

Review of 2022 Arizona Tax Highlights

Lewis Roca on 2/22/2023

ARIZONA TO IMPLEMENT 2.5% FLAT TAX AHEAD OF SCHEDULE - Governor Doug Ducey announced that Arizona will implement its new 2.5% flat income tax rate on January 1, 2023, a full year ahead of schedule. According to Gov. Ducey,...more

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

Buckingham, Doolittle & Burroughs, LLC on 2/17/2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

Freeman Law on 12/5/2022

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Tax Court in Brief | Scheider v. Comm’r | Deficiency for Unreported Income; Burdens of Proof

Freeman Law on 11/7/2022

Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 | Greaves, J. | Dkt. No. 21002-16 Clark Raymond & Company, PLLC v. Comm’r, T.C. Memo. 2022-105 |...more

The Taxpayer Bill of Rights

Freeman Law on 9/27/2022

The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more

District Court Broadly Interprets Informal Claim Doctrine

McDermott Will & Emery on 10/6/2021

Internal Revenue Code (Code) section 7803(a)(3)(C) provides that taxpayers have “the right to pay no more than the correct amount of tax.” However, there are two relevant considerations to this “right.” First, the Internal...more

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

Freeman Law on 8/19/2021

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

Freeman Law on 7/23/2021

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

[Webinar] Freeman Law Legal and Tax Update - March 30th, 1:00 pm CT

Freeman Law on 3/24/2021

Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more

IRS Seizures: The Good, the Bad, and the Ugly

Freeman Law on 10/6/2020

Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance. That is, in part, what makes a recent report from the Treasury...more

Weekly IRS Roundup August 24 – August 28, 2020

McDermott Will & Emery on 9/3/2020

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 24, 2020 – August 28, 2020... August 24 2020: The IRS published a memorandum concerning...more

California OTA to Host Informal IPM to Discuss Possible Amendments to Rules for Tax Appeals

Pillsbury - SeeSalt Blog on 3/26/2020

The California Office of Tax Appeals will hold an informal interested parties meeting on April 3, 2020, to discuss proposed amendments to its rules for tax appeals....more

Weekly IRS Roundup November 11 – 15, 2019

McDermott Will & Emery on 11/21/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 11–15, 2019. November 11, 2019: The IRS released Delegation Order 30-9 announcing the...more

Weekly IRS Roundup September 16 – 20, 2019

McDermott Will & Emery on 9/24/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16 – 20, 2019. September 16, 2019: The IRS issued a news release about time-limited...more

Weekly IRS Roundup August 12 – 16, 2019

McDermott Will & Emery on 8/19/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 12 – 16, 2019. August 12, 2019: The IRS issued a news release announcing that John...more

Taxpayer First Act: Changes to the IRS Appeals Process

McDermott Will & Emery on 7/3/2019

The enactment of the Taxpayer First Act, H.R. 3151 (116th Cong.) (TFA) brings with it several changes to the procedures and operations of the Internal Revenue Service (IRS). The TFA touches on the following subjects... ...more

Jones Day Presents: LB&I Examination Strategies: Process Overview

Jones Day on 6/20/2019

In 2016, the IRS's Large Business & International (LB&I) Division significantly altered its examination processes. In the first in a series of programs on LB&I strategies, Jones Day partner and tax litigator Chuck Hodges...more

California Bill Would Remove Tax Bar to False Claims Act

McDermott Will & Emery on 5/2/2019

California legislators have recently introduced a bill, AB 1270, that would amend the False Claims Act (Act) to strike the tax bar. As introduced, the bill would amend the existing false claims statute in the state of...more

Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office

Jones Day on 3/1/2019

This video is the second in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage two – the IRS Office of Appeals. He describes the office as having one mission – to...more

Weekly IRS Roundup February 18 – 22, 2019

McDermott Will & Emery on 2/25/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 18 – 22, 2019. February 19, 2019: The IRS issued a news release promoting online...more

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on 5/3/2018

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Focus on Tax Controversy - December 2015

McDermott Will & Emery on 12/16/2015

IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court - In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more

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