D.C. Circuit Upholds Tax Court Decision That John Doe Summons Precluded Qualified Amended Return
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D.C. Circuit Upholds Tax Court Decision That John Doe Summons Precluded Qualified Amended Return

ByJustin Hughes

The Lamprecht case is a good reminder of how long and complex the path can be for international taxpayers to correct prior wrongs and come into compliance for federal income tax purposes. On April 23, 2024, in Lamprecht v Commissioner,  ___ F.4th ___ (D.C. Cir. 4/23/24), ( D.C. Circuit Court opinion) the U.S. Court of…

Requirements For NOL Carryforward Utilization Surviving Scrutiny in IRS Examination
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Requirements For NOL Carryforward Utilization Surviving Scrutiny in IRS Examination

ByJustin Hughes

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 to offset business income on Joe and Mary’s 2015 tax return. Joe and Mary’s 2015 tax return is selected by the IRS for…