Maximizing Financial Growth: Insights on HSAs and Smart Investment Strategies with Shaun Eddy
5 Key Takeaways | National State Tax Cases, Issues, and Policy Matters to Watch
The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
Employee Benefits and Executive Compensation: Getting Ready for 2024 - Qualified Plans — Special Edition Podcast
End of Year Tax Planning: Tips for Healthcare Professionals and Practices
Change of Control: Golden Parachute Rules in the Sale Process
4 Key Takeaways | Mid-Year Tax Update
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses with 401(h) Plans
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses With 401(h) Plans
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
COVID-19 Relief in 2021: What Small Businesses Need to Know
The Biden Tax Plan
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
The Freeman Law Project – Episode 21 – The New York Times and President Trump's Taxes
ROCK OF AGES video
On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers
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
In this third installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), I discuss a provision of the Act that may not impact a large segment of the population, but which is interesting and worthy of...more
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
If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more
In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more
In its decision dated February 26, 2025 (7 K 1811/21 K), the Düsseldorf Fiscal Court concluded that legal and consulting fees incurred by the indirect sale of a second-tier subsidiary by the subsidiary are deductible business...more
With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more
Even global icons like Beyoncé, among the wealthiest entertainers on the planet, are not immune to IRS scrutiny. Recently, Queen Bey found herself entangled in a dispute with the Internal Revenue Service (IRS) over an alleged...more
In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more
The IRS’ determinations in a notice of deficiency are generally presumed correct. Therefore, unless specifically excepted by Tax Court Rule or statute, the burden of proof in civil tax proceedings is ordinarily on the...more
Over an objection by the IRS, the Tax Court recently ruled in Kapur v. Commissioner that it could limit discovery and permit statistical sampling of voluminous data related to a claimed research credit. The court refused,...more
The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
The recent Tax Court opinion in Hyatt Hotels Corporation v. Commissioner of Internal Revenue informs a federal income taxpayer about its tax responsibility for funds for a guest reward program: when the taxpayer will be...more
Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more
Summary: Petitioner Gayla Moore was the sole owner of Nevco, Inc. (Nevco), a subchapter S corporation, during the tax years in issue (2014 and 2015). Nevco claimed the section 411 credit for increasing research activities...more
Summary: Since 1982, James William Avery (Avery) was a practicing lawyer, specializing in personal injury law as a solo practitioner primarily in Denver, Colorado for the period 2008–2013 but also some in Indiana during...more
Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses deficiencies for disallowed business expenses claimed by taxpayers, Mathew Craddock and Chasta Craddock. Mr. Craddock was employed...more
Summary: In this 32-page, consolidated opinion, the Tax Court addresses deficiencies from disallowance of a 26 U.S.C. § 179D energy efficient building property deduction claimed by Edwards 4 Engineering, Inc. (Edwards), an S...more
Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an alimony deduction claimed by taxpayer Terrence Aragoni. Aragoni divorced his wife. By court order, Aragoni was ordered to pay $9,146...more
Summary: This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more
Summary: This is a deficiency case involving taxpayer Hrach Shilgevorkyan (Petitioner) and the IRS’s disallowance of a mortgage interest deduction for tax year 2012. In 2005 Edvard, Petitioner’s brother, purchased the...more
Kyle Simpson and Christen Simpson, husband and wife (the Simpsons), were equal shareholders in a wholly owned S corporation (S Corp). Through S Corp, Mr. Simpson developed open-source software. He was also employed by three...more