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Internal Revenue Code (IRC) Tax Deductions Appeals

McDermott Will & Emery

Hatch-Waxman Litigation Expenses Are Deductible Under Internal Revenue Code § 162(a)

The US Court of Appeals for the Federal Circuit upheld a US Court of Federal Claims ruling that Hatch-Waxman Act litigation expenses are ordinary and necessary business expenses under § 162(a) of the Internal Revenue Code,...more

Proskauer Rose LLP

Wealth Management Update - January 2025

Proskauer Rose LLP on

The January 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.2%, an increase from the December 2024 rate of 5.0%. The January applicable federal rate (“AFR”) for use with...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

McDermott Will & Emery

A Notice of Deficiency Is Not Set in Stone

McDermott Will & Emery on

A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the...more

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