In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more
6/30/2025
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Break-Up Fee ,
Capital Losses ,
Contract Disputes ,
Cooperation Agreement ,
Corporate Taxes ,
Fees ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Mergers ,
Tax Court ,
Tax Deductions ,
Tax Planning
More than 25 years ago, Congress enacted Internal Revenue Code Section 6751(b) to protect taxpayers from the IRS using penalties as a bargaining chip in an effort to coerce taxpayers to settle. Generally, Section 6751(b)...more