Videocast: Section 45Q Carbon Capture and Sequestration (CCS) credit
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
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
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
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
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
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’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
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
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