At issue in Continuing Life Thousand Oaks, LLC. v. Commissioner, affirmed May 21, 2024, was the year of inclusion in gross income of an income item. The disputed years were 2008, 2009, and 2010 -- taxable years that preceded...more
Congress perhaps made an unintended drafting error in the Tax Cuts and Jobs Act (TCJA) when it required a taxpayer to decrease its deduction for research and experimental expenditures....more
Altria Group, Inc. v. United States, a federal income tax case pending in federal district court in Virginia, shows the importance of laying groundwork for litigation long before a complaint is filed. At issue is a difficult...more
A tax case pending in the United States Supreme Court, Moore v. United States, may cause a cataclysmic change in the federal income tax. The 16th Amendment to the United States Constitution empowers Congress to impose “taxes...more
8/18/2023
/ Apportionment ,
Certiorari ,
Constitutional Challenges ,
Controlled Foreign Corporations ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
SCOTUS ,
Sixteenth Amendment ,
Tax Cuts and Jobs Act
Key Takeaways:
..A pending U.S. Tax Court case presents an interesting theory to preclude the federal income tax disallowance of all deductions of a marijuana business.
..The theory rests on a provision in the 2017 Tax...more