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Tax Liability › Summary Judgment

Cadwalader, Wickersham & Taft LLP

Tax Court Denies SECA Exception to Soroban

Cadwalader, Wickersham & Taft LLP on

The Tax Court recently ruled for the IRS in another case involving the “limited partner exception” under the Self Employment Contributions Act (SECA). Code Section 1402(a)(13) generally exempts the distributive share of...more

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

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

Rivkin Radler LLP on

An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

A&O Shearman

Arrest of helicopter for unpaid tax did not frustrate contract

A&O Shearman on

If a contract allocates the risk of a given event, it is unlikely that event will give rise to a defence of frustration....more

Morris James LLP

Chancery Addresses Ripeness for Indemnification Claims Concerning Tax Liabilities

Morris James LLP on

Hill v. LW Buyer LLC, C. A. No. 2017-0591-MTZ (Del. Ch. July 31, 2019). As this summary judgment decision illustrates, even where parties to a securities purchase agreement agree on a buyer’s entitlement to indemnification...more

Carlton Fields

Plaintiffs’ Notice That the ‘Taxman Cometh’ Was Sufficient to Trigger Statute of Limitations

Carlton Fields on

In a November 16, 2017 ruling, a California appellate court affirmed a summary judgment ruling in favor of several financial advisors, and insurer American General Life Insurance Company, holding that plaintiffs’ fraud and...more

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