The 35% penalty under I.R.C. section 6677 for failing to report a distribution from a foreign trust applies against a person who is both the beneficiary and grantor/owner of a foreign trust. At least, that is now the rule...more
Section 280E of the Internal Revenue Code prohibits taxpayers who are engaged in the business of trafficking certain controlled substances (including, most notably, marijuana) from deducting typical business expenses...more
This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more
8/19/2021
/ CPAs ,
Estate Tax ,
Federal Rules of Evidence ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Legal Ethics ,
Subject Matter Jurisdiction ,
Tax Court ,
Tax Litigation ,
Webinars
The Week of April 26 – April 30, 2021 -
Plentywood Drug, Inc. | April 26, 2021 | Holmes| Dkt. No. 17753-16 -
Short Summary: The Tax Court was asked to decide whether rent paid by the Taxpayer was reasonable. The...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.
The Week of February 8 – February 12, 2021 -
BM Construction v....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.
The Week of January 25 – January 29, 2021 -
Costello v. Comm’r, T.C....more
2/8/2021
/ Abuse of Discretion ,
Charitable Deductions ,
Farms ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Rental Income ,
Rental Property ,
Startups ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Liens ,
Tax Returns
The 2020 year was . . . well, interesting. So, too, were the Tax Court decisions for the year. In this Insight, Freeman Law takes a closer look at the top 10 Tax Court cases of 2020.
As a reminder, Freeman Law...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
11/24/2020
/ C-Corporation ,
Corporate Taxes ,
Corporate Understatements ,
Deficiency Notices ,
Foreign Affiliates ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Returns ,
Transfer Pricing
The IRS has been focused on enforcement efforts targeting conservation easement transactions. And IRS data indicates that more enforcement efforts lie ahead. The Senate Finance Committee, which has been engaged in a...more
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
10/8/2020
/ FBAR ,
Filing Requirements ,
Foreign Corporations ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Statute of Limitations ,
Tax Returns
Sensitive audits present the tax practitioner with unique challenges. They require the exercise of judgment and discretion, as well as an understanding of administrative procedure and even a command of constitutional and...more
10/1/2020
/ Accountants ,
Civil Liability ,
Criminal Investigations ,
Evidence Suppression ,
Fifth Amendment ,
Fourth Amendment ,
Internal Revenue Code (IRC) ,
IRS ,
Parallel Proceedings ,
Privileged Communication ,
Risk Mitigation ,
Tax Audits ,
Tax Fraud ,
Tax Penalties ,
Tax Returns