Tax Court

Corporate, International Tax, Tax Court

Tax Court Addresses a Difference in Dates in the TCJA

By TL Fahring Aug 30, 2024
Collection Due Process, Collection Due Process (CDP), IRS Collection, Tax Court, Tax Treaty

Tax Court Says No Collection Due Process Rights in Connection with Treaty Mutual Collection Assistance Request

By TL Fahring Aug 23, 2024
Federal Income Tax, Tax Court, Tax Litigation Insights

Tax Court Decision Shows Potential Pitfalls when Claiming Settlements Qualify for Federal Income Tax Exclusion

By TL Fahring May 10, 2024
Form 5471, Penalties, Tax Court

The IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

By Jason B. Freeman Apr 12, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Estate of Hoenshied v. Commissioner | Anticipatory Assignment of Income, Charitable Contribution Deduction, and Qualified Appraisals

By Freeman Law Apr 07, 2023
Estate Tax, Tax Court, The-Tax-Court-in-Brief Insights, Trust & Estate Litigation

Tax Court in Brief | Estate of Spizzirri v. Commissioner | Gifts, Bequests, Deductible Expenses, and Estate Tax

By Freeman Law Mar 10, 2023
Collection Due Process (CDP), Criminal, Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Dawveed v. Comm’r | Restitution-Based Assessment and Collection Due Process

By Freeman Law Mar 10, 2023
Settlements, Tax Court, The-Tax-Court-in-Brief Insights, Trusts

Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust

By Freeman Law Mar 10, 2023
Cross-Border Tax Insights, Form 3520, International Tax, IRS Collection, Tax Court, Trusts

Taxpayers’ Failure to File Form 3520 and Form 3520-A Results in Extended Statute of Limitations Period: the Cautionary Tale of Fairbank

By Jason B. Freeman Mar 03, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Commonwealth Underwriting & Annuity Servs. v. Comm’r | Denial of Exemption Under IRC 501(c)(15)

By Freeman Law Mar 03, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Moore v. Comm’r | Research Credit and Computation of Research Expenses under Section 41(a)

By Freeman Law Feb 24, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Fairbank v. Comm’r | Reporting Obligations for Foreign Trust Income and Ownership; Statute of Limitations

By Freeman Law Feb 24, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Avery v. Comm’r | Collection Due Process and a Lawyer’s Race Car Business Expense Deductions

By Freeman Law Feb 24, 2023
Tax Court, The-Tax-Court-in-Brief Insights

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

By Freeman Law Feb 17, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of Penalty

By Freeman Law Feb 17, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Trice v. Comm’r | Reporting Disability Income and Lifetime Learning Credit Reduction

By Freeman Law Feb 17, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Patrinicola v. Comm’r | Taxability of Pension Distributions

By Freeman Law Feb 17, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Thomas v. Comm’r | Interpretation of Section 6015(e)(7)(B): “Newly Discovered or Previously Unavailable Evidence”

By Freeman Law Feb 17, 2023