Penalties, Tax Court, Tax Liability

Tax Cout in Brief | Christiansen v. Commissioner

Freeman Law on 7/3/2025

The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose....more

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

Frost Brown Todd on 6/25/2025

Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Employers Are Obligated to Comply with Tax Law Despite Increase in Frivolous Tax Arguments

Littler on 5/20/2025

In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

Allen Barron, Inc. on 2/13/2025

Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

No More Lists – IRS Concedes on Reportable Transaction Penalties

Baker Donelson on 1/8/2025

Following the 11th Circuit's ruling in Green Rock LLC v. IRS this past summer, the IRS has decided to cease its defense of post-American Jobs Creation Act (AJCA) reportable transaction notices. In an Action on Decision memo...more

A “Thriller” in Tax Court: The Estate of Michael Jackson and IRS Dispute Valuation of Pop Star’s Image

Bowditch & Dewey on 3/20/2017

How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more