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9 Aug 2014, 8:49 am
Below is Part 6 and the conclusion of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. [read post]
29 Mar 2015, 3:10 pm
And they tend to be folks that will bet on their sentimental favorites or their gut as opposed to a well thought out analysis. [read post]
7 Jun 2014, 5:38 am
The recent jury verdict in the Zwerner case in Miami, Florida (U.S. v. [read post]
18 May 2012, 4:49 am
These questions cannot be answered by logical analysis. [read post]
5 Mar 2018, 6:41 am
Hutchinson v. [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]
4 Mar 2015, 8:28 pm
Justice Kennedy’s questions suggested he might be a fifth vote to uphold the IRS tax credit rule on the grounds of “constitutional avoidance. [read post]
9 May 2009, 5:02 pm
In Cassman v. [read post]
20 Mar 2020, 9:48 am
The Opinion in Brooks v. [read post]
14 Oct 2017, 11:46 am
In Kaufman v. [read post]
24 Jun 2015, 11:36 am
His prior posts on the lawsuits challenging the IRS tax credit rule can be found here and here. [read post]
23 Aug 2006, 9:37 am
The TaxProf Blog [pointed out via Instapundit ] reports the decision in Murphy v. [read post]
26 May 2015, 9:00 pm
Last week, the Supreme Court issued a ruling in Comptroller of the Treasury of Maryland v. [read post]
17 Jul 2010, 6:39 pm
The Tax Court then began to apply its analysis to the facts of the case, and it wasn’t hard to tell where the Court was going. [read post]
23 Jan 2007, 4:19 pm
Banks, and Vincent v. [read post]
1 Aug 2010, 6:36 pm
Then, with the irreparable harm proven, once the "sliding scale" analysis is applied, the likelihood of success on the merits threshold becomes fairly low. *** Alliance for the Wild Rockies v. [read post]
26 Jul 2010, 10:48 am
Technorati Tags: US Tax Court, charitable organization, Free Fertility Foundation v. [read post]
7 Sep 2015, 7:35 am
The government attorneys noted the case of International Proprietaries, Inc. v. [read post]
12 Jan 2010, 10:28 pm
” Deputy v. [read post]
22 May 2018, 5:30 am
It is generally difficult to track the level of capital income in retirement accounts, especially because it does not show up on Internal Revenue Service (IRS) forms until it is distributed.[5] The information gleaned from IRS forms, though, reveals that retirement distributions are a significant source of income for the middle class. [read post]