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Internal Revenue Code (IRC) Tax Litigation Income Taxes

Foster Garvey PC

Hobby Loss Rules Revisited

Foster Garvey PC on

With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Allen Barron, Inc.

The Appeal of an IRS Audit is Based Upon the Audit's Examination File

Allen Barron, Inc. on

Did you know the appeal of an IRS audit is based upon the IRS examination file record of the audit itself? When the IRS produces its "Notice of Determination" at the end of an audit, a very important door closes: the ability...more

Mayer Brown

Surk v. Commissioner: Excess Losses Claimed in Closed Years Reduce Current Tax Basis

Mayer Brown on

Children learn certain social norms through game playing. In hide and seek, when the seekers exclaim, “alley alley oxen free!” the children in hiding are free to return to home base. It would violate a child’s sense of...more

Gray Reed

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

Gray Reed on

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

Freeman Law

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

Freeman Law on

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

Freeman Law

The Taxpayer Bill of Rights

Freeman Law on

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

McDermott Will & Emery

District Court Broadly Interprets Informal Claim Doctrine

McDermott Will & Emery on

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

Freeman Law

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

Freeman Law on

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

McDermott Will & Emery

Weekly IRS Roundup August 24 – August 28, 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

McDermott Will & Emery

Weekly IRS Roundup August 12 – 16, 2019

McDermott Will & Emery on

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

McDermott Will & Emery

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

McDermott Will & Emery on

Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more

McDermott Will & Emery

Weekly IRS Roundup February 18 – 22, 2019

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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

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