On November 20, 2018, the IRS issued a memo on “Updated Voluntary Disclosure Practice” (the “Memo”). The Memo sets forth guidance for both domestic and offshore related voluntary disclosures after the recent …
Overview In Judge v Comptroller, No. 17-IN-00-0724 (Sept. 25, 2018)(link), the Maryland Tax Court overturned the Maryland Comptroller’s finding that Petitioner was personally liable for Maryland income tax withholdings for the period …
In order to avoid the flow-through of examination adjustments, the Taxpayer in Mowry v Commissioner[1] attempted to argue that an S corporation, in which he was a minority shareholder, had ceased to …
In Garcia v. Commissioner [1], the Taxpayers were a married couple embroiled in litigation over alleged corporate fraud by an international bank specialist. The specialist’s fraud devalued the couple’s minority interest in …
Joe and Mary operate a closely held business that generates a net operating loss in 2005 and 2007. The net operating loss from 2005 and 2007 are carried forward and are used …
In Hirsch v. Commissioner (here) the Tax Court held that the taxpayer’s “tax home” for purposes of the foreign earned income exclusion (I.R.C. section 911) was in the New York metropolitan area, …
Flume v. Commissioner (here) revolved around one noteworthy issue: did the taxpayer’s reliance on the advice of his tax return preparer spare the taxpayer from $110,000 in penalties for the taxpayer’s failure …
In Goldsmith v. Commissioner, T.C. Memo. 2017-20 (link) the Tax Court held that the payments from the shareholder’s S corporation were not wages. The Tax Court reasoned that the payments to the …
The taxpayer in Shaffran v Commissioner, T.C. Memo. 2017-35 (link) was not an owner, officer, or employee of a restaurant that got behind in its federal payroll taxes. Yet, the IRS still …
Takeaway: When calculating insolvency for purposes of the insolvency exclusion of cancellation of indebtedness income, a pension plan may or may not be considered an “asset”. The determination depends on whether the …
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