News & Analysis as of

Tax Liability Internal Revenue Code (IRC) Tax Litigation

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

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

Freeman Law

Freeman Law’s Top 10 Tax Court Cases of 2020

Freeman Law on

The 2020 year was . . . well, interesting. So, too, were the Tax Court decisions for the year. In this Insight, Freeman Law takes a closer look at the top 10 Tax Court cases of 2020. As a reminder, Freeman Law...more

McDermott Will & Emery

What Happens At Exam, Stays At Exam!

McDermott Will & Emery on

A recent case decided by the US Tax Court reminds us that when you litigate a case in Tax Court, what happened during the Internal Revenue Service (IRS) examination and Appeals bears very little relevance (if any) once you...more

McDermott Will & Emery

Weekly IRS Roundup February 18 – 22, 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 February 18 – 22, 2019. February 19, 2019: The IRS issued a news release promoting online...more

McDermott Will & Emery

Federal Circuit Narrowly Interprets Limitations Period for Foreign Tax Credit Refund Claims

In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...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