The Tax Court in Brief February 14 – February 18, 2022 - 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
The Tax Court in Brief February 14 – February 18, 2022 - 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
Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Slone v. Commissioner Slone v. Comm’r, T.C. Memo 2022-6 | February 7, 2022 | Lauber, J. | Dkt. Nos. 6629-10, 6630-10, 6631-10, 6632-10...more
Tax Litigation: The Week of February 7 – February 11, 2022 TBL Licensing LLC v. Commissioner Slone v. Commissioner U.S. Tax Court Summaries Larry T. Williams v. Comm’r, T.C. Memorandum 2022-7 February 7, 2022 | Urda, J. |...more
Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Sloane v. Commissioner TBL Licensing LLC v. Comm’r, Corrected 158 T.C. 1 | February 8, 2022 | Filed January 31, 2022 | Halpern, J. | Dkt. No....more
On January 3, 2009, an alternative currency was born, known as Bitcoin—a cryptocurrency or virtual currency secured through digital blockchain technology, allowing electronic monetary transactions from person to person...more
Trusts - Trusts play an important role in estate and tax planning. A trust is a fiduciary arrangement that allows a trustee to hold legal title to assets for the benefit of a beneficiary. The beneficiary is, in turn, said...more
U.S. taxpayers are generally taxed on their worldwide income. But what happens when that income is also taxed by another country? The Internal Revenue Code’s primary mechanism to alleviate this double taxation of income is...more
Section 1202 offers a once little-known exclusion from income for gain on qualified small business stock (“QSB stock”). The provision has undergone substantial revisions over the years and came back into vogue as a result of...more
A regulated investment company (“RIC”) is an electing domestic corporation that either meets (or is excepted from) (i) registration requirements under the Investment Company Act of 1940, (i) that derives at least 90 percent...more
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
2/7/2022
/ Deficiency Notices ,
ESOP ,
Fiduciary Duty ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Liability ,
Tax Liens ,
Tax Planning ,
Tax Returns
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
U.S. citizens and resident aliens who live abroad are taxed on their worldwide income. But such taxpayers may qualify for the foreign earned income exclusion, which allows certain taxpayers to exclude up to $112,000 (in...more
Amid the crypto boom, mining has become an extremely lucrative venture for many and critical to maintaining decentralized cryptocurrency networks. It is no surprise then that mining has been subject to IRS scrutiny and...more
Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L -
Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more
1/21/2022
/ Abuse of Discretion ,
Deficiency Notices ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Jurisdiction ,
Tax Court ,
Tax Levy ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Whistleblowers
This year has been a banner year for cryptocurrencies, with the prices of Bitcoin and Ethereum reaching all-time highs in November. Undoubtably, margin trading – the borrowing of capital from a broker or a margin lender to...more
Tax Litigation: The Week of December 19 – December 25, 2021 -
William R. Huff and Cathy Markey Huff, v. Comm’r, T.C. Memorandum 2021-140| December 21, 2021 | Urda, J. | Dkt. No. 22604-17.
Short Summary: The main issue...more
In the recent case of United States v. Hughes, a federal district court upheld willful FBAR penalties against a taxpayer for failing to report foreign accounts. The court, siding with the government in two out of four years...more
In the recent case of Heiting v. United States, the Seventh Circuit Court of Appeals denied the taxpayer’s claim-of-right deduction pursuant to Internal Revenue Code section 1341. The case stemmed from the taxpayer’s attempt...more
Tax Litigation: The Week of December 13 – December 18, 2021 -
Antonyan, et. al. v. Comm’r, TC Memo. 2021-138 | December 13, 2021 | Nega, J. | Dkt. No. 13741-18 -
Short Summary: In 2012 or 2013, Mr. Antonyan purchased...more
In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more
In the recent case of Todisco v. Commissioner of Internal Revenue, the Tax Court granted innocent spouse relief to the taxpayer, finding that it would be inequitable to hold her liable for the taxes at issue. As a result,...more
Tax Litigation: The Week of December 6 – December 10, 2021 -
Coggin v. Comm’r, 157 T.C. No. 12 | December 8, 2021 | Weiler, J. | Dkt. No. 21580-19 -
Short Summary: Alice J. Coggin (“Coggin”), who was married during...more
A settlement agreement can be beneficial to all parties – it may help reduce litigation costs, facilitate dispute resolution, or guide the parties to a common understanding. However, settlement agreements do not come without...more
The U.S. Congress passed the Tax Cuts and Jobs Act (TCJA) in late 2017, substantially overhauling the Internal Revenue Code of 1986. The TCJA highlighted the importance of several often-overlooked provisions in the Tax Code....more