Tax Court

Form 5471, Penalties, Tax Court

IRS Lacks Statutory Authority to Assess Certain Form 5471 Penalties

By Matthew L. Roberts 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 Matthew L. Roberts 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
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | 3M Company v. Comm’r | Allocation of Income for Subsidiary License or Use of Intellectual Property; Validity of Treas. Reg. 1.482-1(h)(2))

By Freeman Law Feb 10, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Rawat v. Comm’r | Nonresident Alien Individual and Sale of Partnership Interest Attributable to Inventory in U.S.

By Freeman Law Feb 10, 2023
Tax Court, The-Tax-Court-in-Brief Insights

Tax Court in Brief | Craddock v. Comm’r | Deficiency for Disallowed Business and Travel Expenses

By Freeman Law Feb 03, 2023