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Internal Revenue Code (IRC) Summary Judgment Tax Court

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

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