The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions.
In a July 19, 2024, order in...more
The Third Circuit challenges the long-held view that the timing requirements for Tax Court review of a notice of deficiency preclude any extension or delay of the filing deadline.
Culp v. Commissioner is the first case in...more
The Tax Court’s decision setting aside IRS Notice 2017-10 for ignoring the APA’s notice and comment requirements has serious implications for other notices identifying listed transactions.
Key Points:
..Notice 2017-10...more
Updated guidance relieves most tax deadlines, provides new procedures for claiming tax relief, and addresses communications with the IRS during the widespread shutdown.
...more
Notice 2020-18, expanded by Notice 2020-20, provides welcome economic relief from filing and payment obligations for certain federal taxes; however, traps for the unwary exist.
Tax Deadline – Key Points:
..On March 20,...more
Notice 2020-18 provides welcome economic relief from filing and payment obligations for certain federal income taxes; however, traps for the unwary exist.
Tax Deadline – Key Points:
..On March 20, 2020, the Internal Revenue...more
3/26/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
Filing Deadlines ,
Income Taxes ,
IRS ,
Office Closures ,
Popular ,
Relief Measures ,
State of Emergency ,
Tax Court ,
Time Extensions