Search for: "Tax Analysis v. Irs"
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13 Jun 2024, 12:43 pm
In Strom v. [read post]
9 Jun 2024, 9:00 pm
Circuit’s decision in Blassingame v. [read post]
5 Jun 2024, 2:36 pm
Challenging the 2039 IRS Summons as a Whole First, there will be a legal analysis of the “Powell factors,” as delineated by SCOTUS in U.S. v. [read post]
6 May 2024, 9:17 pm
The Tax Court had held that the IRS lacked authority to collect the penalties administratively and was required to file suit to collect. [read post]
4 May 2024, 7:00 am
As we wrote recently in our analysis of Reich v. [read post]
18 Apr 2024, 6:26 am
The Supreme Court’s Muldrow v. [read post]
21 Mar 2024, 1:01 pm
The Tax Court held in Soroban Capital Partners LP v. [read post]
1 Mar 2024, 6:10 am
States have often adopted measures against perceived violations of erga omnes obligations by other States, and the recent round of sanctions taken by several (though mainly western) States in response to Russia’s aggression against Ukraine is the latest example (for a detailed analysis of earlier practice see Tams, Katselli Proukaki, and Dawidowicz). [read post]
20 Feb 2024, 4:56 pm
For an interesting illustration of the granularity of “deduct versus capitalize” analysis in the pharmaceutical industry, see IRS AM 2014-006. [read post]
6 Feb 2024, 3:58 pm
The Supreme Court’s 2023 decision in Groff v. [read post]
4 Jan 2024, 12:55 pm
In Philadelphia Energy Solutions Refining and Marketing, LLC v. [read post]
13 Nov 2023, 4:07 am
The LLC movement stalled until 1988 when the IRS issued Revenue Ruling 88-76 recognizing pass-through partnership tax classification for the Wyoming LLC. [read post]
25 Oct 2023, 12:11 pm
These are the ones that are supposed to come wrapped in IRS Form 709; the United States Gift Tax Return. [read post]
13 Sep 2023, 11:46 am
”Mark D., tax attorney “This is an enormously helpful free resource to those of us in grassroots community legal matters. [read post]
17 Aug 2023, 6:37 am
IRS, the D.C. [read post]
17 Aug 2023, 6:37 am
IRS, the D.C. [read post]
19 Jul 2023, 6:00 am
The analysis here is very complex. [read post]
18 Jun 2023, 9:00 pm
He sought to weaponize the IRS to audit his perceived political enemies--which could potentially turn up evidence of additional tax liability and even prosecutable offenses. [read post]
5 Jun 2023, 6:25 am
The Supreme Court recognized in Mayo Foundation v. [read post]
24 May 2023, 6:37 am
Cohen as income to the New York State tax authorities. [read post]
