News & Analysis as of

Treasury Regulations Tax Court

Miller Canfield

In a Pending Research Tax Credit Case the IRS Fails to Follow Regulatory Language

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The stream of cases challenging disallowance of research tax credits continues in the Tax Court with Phoenix Design Group, Inc. v. Commissioner. The taxpayer in Phoenix Design designs mechanical, electrical, and plumbing...more

Freeman Law

Tax Court in Brief | Scheizer v. Comm’r | Charitable Contribution Substantiation and Reliance on Tax Professional

Freeman Law on

Tax Litigation:  The Week of October 3rd, 2022, through October 7th, 2022 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 | Morrison, J. | Dkt. No. 22472-16...more

Freeman Law

Tax Court in Brief | Medtronic, Inc. v. Comm’r | Section 482, Comparable Uncontrolled Transaction, Comparable Profits Method

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Tax Litigation:  The Week of August 15th, 2022, through August 19th, 2022 Medtronic, Inc. v. Comm’r, T.C. Memo. 2022-84 | August 18, 2022 | Kerrigan, J. | Dkt. No. 6944-11. Short Summary: This opinion regards a transfer...more

McDermott Will & Emery

Sixth Circuit Denies Proceeds Regulation Rehearing Request, Sets Up a Circuit Split

McDermott Will & Emery on

The US Court of Appeals for the Sixth Circuit recently denied a taxpayer’s request for a rehearing en banc in Oakbrook Land Holdings, LLC v. Commissioner, No. 20-2117, leaving a highly contested conservation easement...more

Freeman Law

Tax Court in Brief | AptarGroup, Inc. v. Comm’r | Foreign Tax Credits and Interest Expense Allocation and Apportionment

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Tax Litigation: The Week of March 14, 2022, through March 18, 2022 Hamilton v. Comm’r, T.C. Memo. 2022-21 | March 15, 2022 |Urda, J. | Dkt. No. 139-19L Pickens Decorative Stone, LLC v. Comm’r, T.C. Memo. 2022-22 | March 17,...more

Freeman Law

Tax Court in Brief | Estate of Levine v. Commissioner | Split-Dollar Life Insurance and Estate Planning

Freeman Law on

Tax Litigation:  The Week of February 28, 2022, through March 4, 2022 - Shaddix v. Comm’r | TC Memo. 2022-11 | February 28, 2022 | Lauber, J. | Dkt No. 12683-20L - Estate of Kazmi v. Comm’r, T.C. Memo. 2022-13| March 1,...more

McDermott Will & Emery

A Look Back at Supreme Court Justice Breyer's Tax Opinion in Home Concrete

On January 27, 2022, Supreme Court of the United States Justice Stephen Breyer formally announced his retirement, effective when the Supreme Court breaks for summer recess in June or July later this year—after his successor...more

Mitchell, Williams, Selig, Gates & Woodyard,...

The Case Against Do-It-Yourself Tax Returns: You Don't Know What You Don't Know

In an effort to comply with the increasing complexity of the Internal Revenue Code (the “Code”) and the regulations promulgated thereunder, many taxpayers are looking to tax preparation software for assistance in preparing...more

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