Insights

The Methods (and Madness) of Transfer Pricing for Tangible and Intangible Property

Tax Court in Brief | Richard J. O’Neill Trust v. Comm’r | Application for Tentative Refund, Claim of Right, Mitigation, and Equitable Recoupment

Tax Court in Brief | Manzolillo v. Comm’r | Preclusion for Deficiency Determination, IRS Form 8962 and Premium Tax Credit

Whirlpool Petition for Cert

Plan Loan Offsets | What happens to a loan against a qualified retirement plan when the plan or employment is terminated?

Withdrawal of 2006 Proposed PTEP Regulations

Tax Court in Brief | Yaguda v. Comm’r | Taxation of Unearned Income of Child; Income from S Corp; Accuracy-Related Penalty

Tax Court in Brief | Champions Retreat Golf Founders, LLC v. Comm’r | Conservation Easement Valuation; Highest and Best Use; Battle of Experts

Gain Recognition Agreements and Outbound Stock Transfers

Tax Court in Brief | Clark Raymond & Co., PLLC v. Comm’r | Partnership Intangible Assets, Economic Effect and Treas. Reg. § 1.704-1

Tax Court in Brief | Scheider v. Comm’r | Deficiency for Unreported Income; Burdens of Proof

Tax Court in Brief | Cochran v. Comm’r | Tax Court Proceeding and Automatic Stay in Bankruptcy

Service of Process on a Decentralized Autonomous Organization

Texas Tax Round Up | September 2022

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

Tax Court in Brief | Sander v. Comm’r | Standing to Contest Deficiency of Another

Section 245A Overview and Requirements

TIGTA Finds IRS Is Not Always Following Procedures for Tax Liens.