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Internal Revenue Service › Summary Judgment › 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.  
Cadwalader, Wickersham & Taft LLP

Tax Court Denies SECA Exception to Soroban

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The Tax Court recently ruled for the IRS in another case involving the “limited partner exception” under the Self Employment Contributions Act (SECA). Code Section 1402(a)(13) generally exempts the distributive share of...more

Fenwick & West LLP

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

Fenwick & West LLP on

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

Fox Rothschild LLP

Tax Court to Revisit Problematic Economic Substance Ruling

Fox Rothschild LLP on

Last October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for summary judgement and found that contrary to...more

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

Rivkin Radler LLP on

An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

Allen Barron, Inc.

A Decision in US Tax Court Affects Limited Partners and SECA

Allen Barron, Inc. on

A recent decision in the US Tax Court affects limited partners and SECA – the Self Employed Contributions Act. In this case, Soroban Capital Partners LP (a hedge fund management company) was formed as a Delaware limited...more

Husch Blackwell LLP

U.S. Tax Court Finds "Disqualified Person" Definition For Nonprofit Excess Benefit Rules Is Expansive

Husch Blackwell LLP on

On May 17, 2021, the U.S. Tax Court issued a Memorandum Opinion in Vincent J. Fumo v. Commissioner, T.C. Memo. 2021-61, regarding the definition of a “disqualified person” under I.R.C. section 4958(a)(1). Managers of...more

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