News & Analysis as of

Tax Liability Appeals Tax Appeals

Snell & Wilmer

California Office of Tax Appeals Cleared To Consider Whether Tax Regulations Conflict With Statutes

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The California Attorney General (AG) recently issued Legal Opinion No. 23-701 stating that the California Office of Tax Appeals (OTA) has the authority to determine whether tax regulations issued by the Franchise Tax Board...more

Dickinson Wright

Tax Planning Misstep? Ontario Court of Appeal Says No to Rectification

Dickinson Wright on

A recent decision from the Ontario Court of Appeal is a good reminder that courts won’t bail you out just because a tax plan didn’t go as expected. In Pyxis Real Estate Equities Inc. v. Canada, 2025 ONCA 65, the Court made it...more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

Allen Barron, Inc. on

Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Cadwalader, Wickersham & Taft LLP

YA Global Brings its Fight to the Appellate Level

On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more

Blank Rome LLP

If You Don’t Ask, The Answer’s Always No

Blank Rome LLP on

One of the first rules of business is that you don’t leave money on the table. That adage is equally important in tax matters. Taxpayers can leave behind funds by failing to follow the rules. The importance of compliance with...more

Mayer Brown

Un courrier rectificatif concernant le type de formulaire déclaratif à utiliser constitue une « prise de position formelle » au...

Mayer Brown on

Dans une décision du 11 mars 2025, le Conseil d'Etat relève qu'un simple courrier rédigé par l'administration en des termes explicites est susceptible de constituer une prise de position formelle de sa part au sens de...more

Saul Ewing LLP

New Castle County Council Introduces Ordinance to Extend Deadline to File a Property Tax Assessment Appeal

Saul Ewing LLP on

Appeal deadline is currently March 14.  Council has introduced an ordinance to extend deadline to March 31, 2025.  The ordinance will not be considered until March 13....more

Holland & Knight LLP

Final Regulations on IRS Appeals Issued

Holland & Knight LLP on

In 2019, Congress introduced Internal Revenue Code Section 7803(e) that codified the IRS Independent Office of Appeals (Appeals) as an administrative avenue for resolving disputes without going to court, focusing on...more

Harris Beach Murtha PLLC

Deadline for CT Real Property Tax Assessment Appeals is Feb. 20

Property owners who wish to challenge their tax assessment believing that their property is overvalued on the Oct. 1, 2024, Grand List only have a couple of weeks left to file a written appeal with the Board of Assessment...more

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