Tax Court
U.S. Tax Court Settlements in IRS Appeals
In Notice 2015-72 the IRS proposes to updateRev. Proc. 87-24 regarding U.S. Tax Court Settlements...
Marijuana Taxation: Beck v. Commissioner & Excise Tax Paid
UGH! I vowed to stop writing about the tax implications of marijuana taxation: Beck v....
Coca Cola’s Recent IRS Statutory Notice of Deficiency – a Tipping Point in International Transfer Pricing Enforcement
In Coca Cola's SEC 8-K filinglast week we learned thatthe IRS issued a $3.3 Billion...
Meal Expense – Navigating Between Internal Revenue Code Sections 162, 274, 132; IRS Technical Advice Memorandum 200030001; and, Churchill Downs v. Commissioner
As per usual I'mswimming inareas where the tax code is seemingly at odds. The latest...
Richard S. Leyh et ux. v. Commissioner – Contemporaneous Log Detailing Rental Property Activity Permissible in Defining Real Estate Professional for Income Tax Purposes
Richard S. Leyh et ux. v. Commissioner (T.C. Summ. Op. 2015-27) details a case in...
Schumann v. IRS: Reg. 1.469-2(f)(6) – The Nuanced Relationship Between Passive Losses & Self Rental Gains
Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental...
Odujinrin v. IRS Commissioner Reinforces the Significance of Engaging a Reputable Enrolled Agent
In Wole Odujinrin v. IRS Commissionerthe petitioner, a hematology oncologist who represented himself, did not...