Aspro, Inc. v. Commissioner, T.C. Memo 2021-8 (January 2021) is a cautionary tale for C corporations that look to zero out taxable income through post hoc management fees. In total the three …
In Grajales v Commissioner, 156 T.C. No. 3 (2021), the Tax Court held the 10% tax in section 72(t) applicable to early distributions from qualified retirement plans is not subject to § …
In Ramey v Commissioner, 156 T.C. No. 1 (2021) (available in Tax Notes free resources here), the IRS mailed a final notice of intent to levy (LT11) to the taxpayer’s last known …
Overview of IRS Rev. Proc. 2020-20 Rev. Proc. 2020-20 (link) provides certain qualifying non-resident aliens some administrative relief for certain extended stays in the U.S. caused by travel disruptions arising during the …
Overview In Reflectxion Resources, Inc. v. Commissioner, T.C. Memo. 2020-114 (August 3, 2020)(link), the U.S. Tax Court held that a Notice of Determination of Worker Classification (“NDWC”) was not in and of …
In U.S. v. Bittner [1](available here: link), the U.S. District Court for the Eastern District of Texas (the “Court”) handed taxpayers a victory by declining to follow the legal analysis in Boyd …
Per an internal IRS memorandum prepared within the IRS SB/SE division (link to memo), the IRS has determined that it will not allow a § 199A deduction when it prepares a substitute …
The issue before the court was whether the taxpayer received a taxable, deemed distribution in 2014 from an account that was treated and consistently reported by the Taxpayer as an IRA even …
On January 15, 2019, the IRS issued a revised IRS Lapsed Appropriations Contingency Plan. Under the revised plan dated January 15, 2019, the IRS is set to recall over 2,000 IRS collections …
In a recent case,[1] the Federal District Court for the District of Maryland held that the U.S.’s federal IRS tax lien did not attach to a piece real property after the transfer …
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