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Internal Revenue Service Appellate Courts

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Holland & Hart LLP

the buzz: Cannabis News & Policy Update | Special Edition for June 2025

Holland & Hart LLP on

In this Court Rips edition of the buzz: IRC §280E limits the ERC for cannabis company - Canna Provisions case is dismissed (again) by Appeals Court....more

Parker Poe Adams & Bernstein LLP

Fourth Circuit Increases Defendants' Exposure in White Collar Cases, Interpreting 'Loss' as Either Actual or Intended Financial...

For years, it has been unsettled in the Fourth Circuit Court of Appeals whether a white-collar defendant may be held accountable for intended loss amounts during sentencing in fraud and other financial harm cases. Prosecutors...more

Cozen O'Connor

Notice of Appeal - A quarterly newsletter reviewing Third Circuit opinions impacting white collar defense lawyers - March 2024

Cozen O'Connor on

Defendant and his co-conspirators firebombed an informant’s house and killed several individuals. Six weeks into their trial on related charges, the Government disclosed that one of the defense attorneys previously worked as...more

Cozen O'Connor

Notice of Appeal - Summer 2023 - A quarterly newsletter reviewing Third Circuit opinions impacting white collar defense lawyers

Cozen O'Connor on

Practice Note- Third Circuit Adopts 5:00 PM Filing Deadline- Effective July 1, 2023, the Third Circuit amended its local rules to require all filings, with the exception of those initiating a new appeal or other...more

McDermott Will & Emery

With the IRS, Mail Delivery Counts!

McDermott Will & Emery on

Over the years, case law has developed around when a mail delivery method is acceptable to prove that a tax filing was made. The US Court of Appeals for the Fourth Circuit’s recent decision in Pond v. United States[1] ...more

McDermott Will & Emery

Supreme Court Denies Certiorari in Whirlpool

McDermott Will & Emery on

On November 21, 2022, the Supreme Court of the United States denied certiorari in Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9. This means that the US Court of Appeals for the...more

Cozen O'Connor

Notice of Appeal - A quarterly newsletter reviewing Third Circuit opinions impacting white collar defense lawyers

Cozen O'Connor on

Precedential Opinions of Note- Conviction for Drug Distribution Overturned for Lack of Proof Playground Was ‘Open to the Public’...more

Rivkin Radler LLP

Statutory Residence in New York: Time to Rethink the “Permanent Place of Abode” Test?

Rivkin Radler LLP on

Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Butane Additive/Gasoline: Federal Appellate Court Addresses Scope of the Alternative Fuel Mixtures Credit

The United States Court of Appeals for the Seventh Circuit (“Seventh Circuit”) addressed in a June 29th Opinion the scope of the alternative fuel mixtures (“AFM”) federal tax credit. See U.S. Venture, Inc., v. United States...more

McDermott Will & Emery

Ninth Circuit Holds Tax Form is Substance

The substance over form doctrine (and related step transaction and economic substance doctrines) are often invoked by courts to disallow tax consequences that seem too good to be true. Courts have struggled for years with how...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

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A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Farrell Fritz, P.C.

Transfer Of Funds between Related Entities – Indebtedness Or Something Else?

Farrell Fritz, P.C. on

A closely held business may come to our firm for any number of reasons. The owners may be selling the business, for example, or they may be thinking about spinning off a division. In some cases, the owners are considering the...more

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