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Settlement Agreements Internal Revenue Service Tax Court

Littler

Recent U.S. Tax Court Opinion Illustrates How Language in Settlement Agreements Can Determine Tax Treatment of Payments

Littler on

In Mennemeyer v. Commissioner,1 the United States Tax Court reminds us that a settlement agreement that is not carefully drafted can have significant tax consequences....more

Freeman Law

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

Freeman Law on

The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters.  In that case, the taxpayer stipulated that he:  (1) had Form 5471 filing obligations...more

Freeman Law

Are Settlement Payments for Emotional Distress Taxable?

Freeman Law on

The proper federal tax treatment for any given settlement payment is something of an enigma. Generally, federal courts (and thus, the IRS) respect the terms of a settlement agreement if the terms are clear and the parties...more

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

Syndicated Conservation Easement Transactions: Internal Revenue Service Announces First Settlement

The Internal Revenue Service (“IRS”) in an August 31st news release announced what it described as: . . . the completion of the first settlement under its initiative to resolve certain docketed cases involving syndicated...more

McDermott Will & Schulte

Tax Court Holds That Form 870-AD Is Not a Binding Settlement Agreement

A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency. In Howe...more

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