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Tax Deductions Tax Court Appeals

Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

Rivkin Radler LLP on

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

Hogan Lovells

Tax relief for predevelopment costs

Hogan Lovells on

In a case that will be of interest to all developers and funders of UK infrastructure and energy projects, Orsted West of Duddon Sands v HMRC [2025] (previously known as Gunfleet Sands v HMRC), the Court of Appeal held that...more

McDermott Will & Schulte

A Notice of Deficiency Is Not Set in Stone

A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the...more

Burr & Forman

Conservation Easements: Building Envelopes Doom Donation

Burr & Forman on

The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation...more

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