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Internal Revenue Code (IRC) Summary Judgment

Freeman Law

Tax Court Has De Novo Review Over Tax-Related Passport Denial/Revocation Cases

Freeman Law on

In a recent case of first impression, the U.S. Tax Court has held that it does not have to rely solely upon the administrative record in determining whether the IRS erroneously certified a taxpayer as having a seriously...more

Fox Rothschild LLP

Tax Court to Revisit Problematic Economic Substance Ruling

Fox Rothschild LLP on

Last October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for summary judgement and found that contrary to...more

Epstein Becker & Green

Not the Day We Are Waiting For - SCOTUS Today

Epstein Becker & Green on

With a significant mass of cases left to decide and only a few weeks to issue the opinions, the U.S. Supreme Court has reduced the backlog by four yesterday. None of them, however, resolves the future of Chevron deference or...more

Rivkin Radler LLP

The Trust Fund Penalty – Times May be Tough, But Don’t “Borrow” from Withheld Taxes

Rivkin Radler LLP on

It’s wonderful to be part of a successful business, especially in a strong economy. The owners are probably enjoying a more than just decent return on their investment and, in most cases, are getting along well enough. The...more

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