On July 3, 2024, the United States District Court for the Southern District of New York held that “users of cellphones are not categorically excluded from the definition of ‘residential subscriber’ under the TCPA (Telephone...more
The substance over form doctrine (and related step transaction and economic substance doctrines) are often invoked by courts to disallow tax consequences that seem too good to be true. Courts have struggled for years with how...more
On Tuesday, the Court of Appeals reversed a trial court’s dismissal of a plaintiff’s complaint seeking entry of a domestic violence protective order against her husband. In Quackenbush v. Groat, the trial court dismissed the...more
On January 28, 2020, the California Office of Tax Appeals (OTA) denied the California Franchise Tax Board’s (FTB) request to rehear In the Matter of the Appeal of Sharon Mitchell (OTA Case No. 18011715). This decision may...more
In Notice 2018-54, the IRS has notified taxpayers that proposed regulations are forthcoming which will deny state attempts to convert a taxpayer’s state and local tax obligations to a charitable deduction in order to avoid...more
A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more