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25 Jun 2008, 2:07 pm
He has suggested that, so long as confidentiality agreements are common in product liability settlements (and they are, of course), the IRS might well take the position that the portion of a settlement received in return for confidentiality is taxable.The good professor notes that Amos has in fact been cited in a few later tax cases -- Braden v Comr, TC Summary Op 2006-78; Green v Comr, TC Memo 2005-250; and Allum v Comr, 2005-177 -- although never for the confidentiality issue,… [read post]
24 Jun 2008, 1:16 pm
Mom further appealed from TC's order denying her motion for visitation, where TC found that it lacked jurisdiction to consider visitation. [read post]
24 Jun 2008, 1:10 pm
Thus, the issue herein is whether the TC's omitted finding involves a matter which was essential to TC's judgment. [read post]
23 Jun 2008, 1:34 pm
Nearly thirty nations participate actively in the TC; nine additional countries monitor the work of the TC as observers. [read post]
23 Jun 2008, 12:15 pm
Thus if the Court cannot decide this case by June 25, 2008, it should rule that TCS's and 3G's votes be "held in escrow" until the Court has resolved this appeal. [read post]
13 Jun 2008, 10:06 pm
CAAF split 3-2 today, ruling that a possible conflict of interest by a trial defense counsel's overlapping assignments as a DC and a TC required additional factfinding. [read post]
12 Jun 2008, 5:30 am
Nicholas Aroney and James Allan (University of Queensland - TC Beirne School of Law and The University of Queensland - T.C. [read post]
8 Jun 2008, 11:17 pm
&tc, &tc.TD: Yes, but instead of gigantic turkey legs, Hipster Faire is where you go to eat Kraft mac-and-cheese and Chef Boyardee Spaghetti O's because it's ironic.Me: WTF is wrong with these people.TD: You're going to blog this, aren't you.Me: Yep. [read post]
4 Jun 2008, 12:35 pm
(TC Memo 2008-128), a case dealing with the minority and marketability discounts applicable to family limited... [read post]
22 May 2008, 2:48 pm
The TC moved to strike PVT Gibson's testimony, but the military judge denied the request.During the TC's rebuttal argument, the military judge overruled a defense objection to the TC's commentary of PVT Gibson's invocation of his Fifth Amendment rights. [read post]
5 May 2008, 1:24 am
The IRS has issued advice, apparently to its employees, on how to deal with this mess:If you receive a call from a taxpayer who has received a $2 refund check and research shows the refund was generated from an EIC credit (TC 768), assure the taxpayer this is not their stimulus payment. [read post]
15 Apr 2008, 1:05 pm
Commissioner, TC Memo. 2008-30, the Wests had obtained an offer in compromise from the IRS, but then violated its terms by failing to pay estimated taxes, failing to timely file tax returns, and failing to pay multiple tax penalties assessed against them during the 5 year period following the acceptance of their offer in compromise. [read post]
14 Apr 2008, 9:58 am
The CA found that had the TC held a hearing, the TC would not have signed the order. [read post]
10 Apr 2008, 1:46 pm
I'm sitting at my desk, drinking red wine, and watching S&TC, season four. [read post]