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Tax Liability Administrative Procedure Act Tax Court

Freeman Law

Tax Court Has De Novo Review Over Tax-Related Passport Denial/Revocation Cases

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In a recent case of first impression, the U.S. Tax Court has held that it does not have to rely solely upon the administrative record in determining whether the IRS erroneously certified a taxpayer as having a seriously...more

Baker Donelson

No More Lists – IRS Concedes on Reportable Transaction Penalties

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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

Freeman Law

Tax Court in Brief | Green Valley Investors v. Comm’r (consolidated) | Notice 2017-10 Deemed Improperly Issued; Syndicated...

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Tax Litigation: The Week of November 7th, 2022, through November 11th, 2022 Fields v. Comm’r, T.C. Summary Opinion 2022-22 | November 10, 2022 | Panuthos, Special Trial J. | Dkt. No. 2925-20S (IRS Automated Underreporter,...more

Polsinelli

SCOTUS Could Vacate Conservation Easement Regulations

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As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more

Freeman Law

Freeman Law’s Top 10 Tax Court Cases of 2020

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The 2020 year was . . . well, interesting. So, too, were the Tax Court decisions for the year. In this Insight, Freeman Law takes a closer look at the top 10 Tax Court cases of 2020. As a reminder, Freeman Law...more

Carlton Fields

Cost-Sharing Regulations Revived By Ninth Circuit

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The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations. The decision, issued on July 24, revives certain regulatory...more

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