Ruesch v. Commissioner, 154 T.C. No. 13 (2020)(link to case in Google Scholar) is the first Tax Court opinion that analyzes the IRS’s ability to certify “seriously delinquent tax debts” to the …
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 …
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