The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
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 United States Tax Court skillfully dodged answering the headline question with a holding on standing. The court decided, however, that IRS appeals officers and IRS appeals team managers are not officers of the United...more
On February 4, 2025, and by unanimous vote, the Brazilian Supreme Court’s (STF) Plenary confirmed that the non-levy of ICMS will only apply from the 2024 fiscal year, with the exception of administrative and judicial...more
The U.S. tax system developed in response to colonial opposition to taxation without representation. As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more
I recently wrote about the Tax Court decision in Northern California Small Business Assistants Inc. v. Commissioner, which addressed whether Section 280E’s denial of tax deductions to marijuana businesses violates the Eighth...more