Deficiency Notice Invalid Because IRS Cannot Prove Last Known Address
The Tax Court held that the IRS failed to prove that it had complied with the procedure set forth in...
Revisiting FIRPTA and Return-of-Capital Distributions
Sep 5, 2024
Thirteen years ago, this author wrote a Tax Clinic item describing the compliance requirements under Sec. 1445(e)(3) for distributions in...
Rights for the R&D Credit and Sec. 174
Aug 29, 2024
Taxpayers claiming research and development (R&D) tax credits for work performed under contract must contend with the exclusion for “funded...
Supreme Court Issues Narrow Opinion Upholding Sec. 965 Transition Tax
Aug 19, 2024
The U.S. Supreme Court on Thursday upheld the constitutionality of the Sec. 965 transition tax in a narrow opinion that...
Limited Partners and Self-Employment Tax: A New Test
Aug 15, 2024
On Nov. 28, 2023, the Tax Court held that to determine whether the distributive share of partnership profits of a...
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