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Internal Revenue Service Capital Losses Tax Court

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 & Knight LLP

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

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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

Fenwick & West LLP

Tax Court Says AbbVie's $1.6B Break Fee Payment to Shire Properly Deducted as Ordinary Expense

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A break fee in a merger-gone-south can be deducted as an ordinary expense, the U.S. Tax Court held today, finding for biopharmaceutical giant AbbVie and rejecting the IRS’s argument that AbbVie must treat the fee as a capital...more

Freeman Law

Tax Court in Brief | Powell v. Comm’r | IRS Forms vs. Statutes – Net Capital Loss Deduction

Freeman Law on

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

Freeman Law

Tax Court in Brief | Musselwhite v. Commissioner | Loss in Sale of Real Estate: Ordinary Loss or Capital Loss?

Freeman Law on

Tax Litigation:  The Week of June 6th, 2022, through June 10th, 2022 Pocock v. Commissioner, T.C. Memo. 2022-55 | June 6, 2022 | Vasquez, J.| Dkt. No. 12558-17 Consolidated with Dkt. No. 23569-17L Spencer v Commissioner, T.C....more

Freeman Law

The Tax Court in Brief - August 2021 #3

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 9 – August 13, 2021 - Manuelito B. Rodriguez &...more

Rivkin Radler LLP

Capital vs Ordinary Loss When An Investment Goes South

Rivkin Radler LLP on

Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more

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