In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more
In a recent order in the The Cannon Corp. v. Commissioner, No. 12466-16, the US Tax Court (Tax Court) held that a redacted email from a revenue agent’s supervisor to the agent regarding a notice of deficiency was not...more
A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the...more
5/28/2019
/ Appeals ,
Charitable Deductions ,
Clerical Errors ,
Deficiency Notices ,
Enhanced Penalties ,
Income Taxes ,
Initial Determination (ID) ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Tax Penalties
A recent case decided by the US Tax Court reminds us that when you litigate a case in Tax Court, what happened during the Internal Revenue Service (IRS) examination and Appeals bears very little relevance (if any) once you...more
4/26/2019
/ Administrative Procedure ,
Burden of Production ,
Deficiency Notices ,
Internal Revenue Code (IRC) ,
IRS ,
Redeterminations ,
Statutory Violations ,
Tax Court ,
Tax Liability ,
Tax Litigation ,
Taxpayers' Bill of Rights
Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these incentives are taxable income under federal income tax law. Internal Revenue...more
4/11/2019
/ Capital Assets ,
Community Development ,
Economic Development ,
Grants ,
Municipalities ,
Non-Taxable Income ,
State and Local Government ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform