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Tax Appeals Due Process

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

Miller Canfield on

Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

Eversheds Sutherland (US) LLP

Happy New Year! New York Court strikes down retroactive decertification of a tax credit

On December 26, 2019, in Matter of Mackenzie Hughes LLP v. New York State Tax Appeals Tribunal, the New York Supreme Court, Appellate Division, held that New York’s retroactive decertification of Qualified Empire Zone...more

White & Case LLP

Taxpayer First Act and the Independent Office of Appeals

White & Case LLP on

The Taxpayer First Act of 2019 ("TFA")1 has passed both chambers of Congress and will likely soon be signed into law by the President. The bill has a wide range of provisions affecting and modernizing the Internal Revenue...more

Buckingham, Doolittle & Burroughs, LLC

Out-of-state businesses with little-to-no connection with Ohio owe commercial activity tax based upon their customers’ subsequent...

Ohio’s 10th District Court of Appeals affirmed the Board of Tax Appeals’ decision upholding commercial activity tax (CAT) assessments issued to a Georgia business with no activities in Ohio and minimal (if any) direction...more

Bradley Arant Boult Cummings LLP

Alabama Receives Significant Upgrade from COST on State Tax Due Process Scorecard

On December 17, the Council On State Taxation (COST) announced that Alabama’s grade in their “Best and Worst of State Tax Administration” scorecard on Tax Appeals and Procedural Requirements, otherwise known as the “Due...more

Akerman LLP

Fourth District Court of Appeal Holds Sales Tax Against Florida Corporation on Out-of-State Sales is Unconstitutional

Akerman LLP on

In American Business USA Corp. v. Department of Revenue, Case No. 4D13-1472 (4th DCA November 12, 2014), the Fourth District Court of Appeal held that an assessment of sales tax pursuant to a provision in Florida's sales tax...more

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