News & Analysis as of

Revenue Procedures Tax Court

Latham & Watkins LLP

Third Circuit: Tax Court Filing Deadline for Deficiency Petitions Not Jurisdictional

Latham & Watkins LLP on

The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline. Culp v. Commissioner is the first case in...more

Morgan Lewis

Taxpayer Victory in US Tax Court Highlights Need for Properly Structuring Partnership Profits Interests

Morgan Lewis on

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a...more

Proskauer - Tax Talks

Tax Court Provides Helpful Guidance on Requirements for Tax-Free Profits Interests

Proskauer - Tax Talks on

On May 3, 2023, the United States Tax Court held in ES NPA Holding, LLC v. Commissioner, T.C. Memo. 2023-55, that the taxpayer’s receipt of interests in a partnership in exchange for services rendered to the sole owner of the...more

Miller Canfield

Disregarding Administrative Tax Guidance Aided the IRS in Two Cases and the Taxpayer in a Third Case

Miller Canfield on

​​​​​​​Three courts - the Supreme Court, the Sixth Circuit, and the Tax Court - recently rejected administrative guidance in tax cases because the guidance was either wrong as applied, unnecessary, or inapplicable. The...more

Freeman Law

Tax Court Grants Innocent Spouse Relief

Freeman Law on

In the recent case of Todisco v. Commissioner of Internal Revenue, the Tax Court granted innocent spouse relief to the taxpayer, finding that it would be inequitable to hold her liable for the taxes at issue.  As a result,...more

Freeman Law

Ponzi Schemes and the Theft Loss Deduction

Freeman Law on

Every few months or so seem to bring new revelations of a Ponzi scheme gone bust.  In the aftermath, erstwhile investors often struggle to be made whole again.  Fortunately, the federal income tax offers options to help,...more

Freeman Law

The Tax Court in Brief - February 2021 #4

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. The Week of February 22 – February 26, 2021 - Llanos v. Commissioner...more

Sullivan & Worcester

IRS Guidance Provides Critical Information on Extended Deadlines for Returns, Payments and Other Time-Sensitive Tax Actions -...

Sullivan & Worcester on

As reported in our recent Client Alert, the IRS continued its series of tax relief announcements related to the COVID-19 emergency when it issued Notice 2020-23. This alert provides more detailed guidance on IRS Notice...more

Latham & Watkins LLP

US Tax Court Exempts Gain on Sale of a Partnership Interest

Latham & Watkins LLP on

Decision could open planning opportunities for non-US partners regarding sale of a partnership interest. The Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner 1 case — which the US Tax Court decided...more

9 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide