Tax Returns, Tax Court, Tax Planning

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

Frost Brown Todd on 6/25/2025

Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Wealth Management Update - March 2025

Proskauer Rose LLP on 3/10/2025

March 2025 AFRs and 7520 Rate - The March 2025 Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 5.40%, which was the same as the February 2025 rate...more

IRS Layoffs May Mean Longer Waits, Audit Delays and Tax Court Battles

Fox Rothschild LLP on 2/25/2025

The Internal Revenue Service (IRS) is expected to lay off approximately 7% of its workforce in the coming weeks, with the possibility of further reductions. It remains unclear which divisions will be most affected or whether...more

New Jersey Tax Court Rules Undistributed Foreign Earnings of CFC Are Not Taxable Dividends

Husch Blackwell LLP on 1/29/2025

A recent decision by the New Jersey Tax Court held that while taxpayers were required to report undistributed income from “deemed repatriation dividends” on their federal tax returns, they were not required to report that...more

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

Rivkin Radler LLP on 1/28/2025

If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Tax Court in Brief | Kemegue v. Comm'r | Additions to Tax for Failure to File

Freeman Law on 2/20/2023

Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses an addition to tax for failure to pay pursuant to section 6651(a)(1) and (2). During 2017 Kemegue lost his job and experienced multiple...more

Section 6751(b) Penalty Approval Circuit Split

Freeman Law on 12/14/2022

Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

Tax Court in Brief | Fields v. Comm’r | IRS Automated Underreporter Program, Gifts from Employer, Accuracy-Related Penalty

Freeman Law on 11/17/2022

Tax Litigation: The Week of November 7th, 2022, through November 11th, 2022 Green Valley Investors, LLC v. Comm’r, 159 T.C. No. 5 | November 9, 2022 | Weiler, J. | Dkt. Nos. 17379-19, 17380-19, 17381-19, 17382-19...more

Tax Court in Brief | Scheizer v. Comm’r | Charitable Contribution Substantiation and Reliance on Tax Professional

Freeman Law on 10/25/2022

Tax Litigation: The Week of October 3rd, 2022, through October 7th, 2022 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 | Morrison, J. | Dkt. No. 22472-16...more

Tax Court in Brief | Patitz v. Comm’r | Schedule A and Schedule C Itemized Deductions and Documentation Requirements

Freeman Law on 10/19/2022

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Powell and Iakovenko v. Comm’r, T.C. Summary Opinion, 2022-19 | Sept. 26, 2022 | Copeland, J. | Docket No. 20268-19S Powell and Iakovenko v....more