The Week of July 26 – July 31, 2021 -
Harrington v. Comm’r, T.C. Memo. 2021-95 | July 26, 2021 | Lauber, J. | Dkt. No. 13531-18 -
Short Summary: Mr. Harrington is a U.S. citizen; his wife is a dual citizen of the...more
A federal district court in Texas recently took up an interesting FBAR issue: whether civil FBAR penalties survive death? That is, if a taxpayer/account holder dies after the IRS assesses an FBAR penalty against them, do the...more
8/10/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
FBAR ,
FinCEN ,
Foreign Bank Accounts ,
IRS ,
Offshore Funds ,
Penalties ,
Reporting Requirements ,
Tax Returns ,
Willful Violations
The Report of Foreign Bank and Financial Accounts (i.e., the “FBAR”) was for many years confined to the lonely backwaters of Title 31 of the United States Code—the intriguingly-named Bank Secrecy Act. For years, compliance...more
The IRS recently concluded its 2021 four-part series of the “Dirty Dozen” tax-related scams. The fourth installment focuses on what the Service refers to as “schemes peddled by tax promoters, including syndicated...more
The IRS recently issued its third installment of the “Dirty Dozen” tax scams—a list of tax-related schemes ranging from fake charities to scams targeting seniors and immigrants. The Service is reminding “taxpayers, tax...more
What is the Report of Foreign Bank and Financial Accounts (FBAR)?
Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights.
During this information-filled...more
7/23/2021
/ Automatic Stay ,
Cryptocurrency ,
Enforcement ,
Income Taxes ,
IRS ,
Reasonable Compensation ,
State Taxes ,
Tax Benefits ,
Tax Court ,
Tax Litigation ,
Tax Planning ,
Webinars
In a recent Chief Council Advisory, the IRS found that certain cryptocurrencies did not qualify as like-kind exchanges under section 1031 prior to the Tax Cuts & Jobs Act of 2017. The IRS’s ruling, while limited to coin...more
7/22/2021
/ Bitcoin ,
Cryptocurrency ,
Ethereum ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
New Guidance ,
Section 1031 Exchange ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Virtual Currency
In a recent decision, a federal district court found that a long-time CPA/tax-return preparer recklessly failed to file FBARs to disclose several foreign financial accounts. As avid readers of our Insights are aware, many...more
What are the tax consequences of unwinding a transaction? And just when, if ever, is a taxpayer entitled to the transactional equivalent of a mulligan—a do-over? The ability to unwind a transaction depends upon 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 July 5 – July 9, 2021 -
Peterfreund v. Commissioner,...more
This CLE paper explores criminal intellectual property violations. There are a wide range of potentially applicable statutory provisions. Part One broadly discusses criminal copyright infringement, focusing on 17 U.S.C....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 June 21 – June 25, 2021 -
Ervin v. Commissioner, T.C....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 June 14 – June 18, 2021 -
Bell Capital Management, Inc....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
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 May 3 – May 7, 2021 -
Chancellor v. Comm’r, T.C. Memo....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 22 – February 26, 2021 -
Llanos v. Commissioner...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 15 – February 19, 2021 -
Kramer v. Comm’r, T.C....more
3/8/2021
/ Burden of Production ,
Burden of Proof ,
Deficiency Notices ,
Discovery ,
Document Productions ,
Gift-Tax Return ,
IRS ,
Limited Liability Company (LLC) ,
Rules of Practice ,
Tax Court ,
Tax Deductions
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
Kennedy v. Comm’r, T.C. Memo. 2021-3 | January 12, 2021 | Copeland, E. | Dkt. No. 5687-17W -
Short Summary: Petitioner appealed, pursuant to § 7623(b)(4), three determinations of the Whistleblower Office (WBO) of 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 January 18 – January 22, 2021 -
Adams Challenge (UK)...more
1/27/2021
/ Business Expenses ,
Foreign Corporations ,
Income Taxes ,
International Tax Issues ,
Investment Management ,
IRS ,
Management Fees ,
Shareholder Distributions ,
Tax Deductions ,
Tax Planning ,
Tax Returns ,
Tax Treaty
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