The Ninth Circuit has once again reversed the Tax Court in Altera v. Commissioner. The case was reheard after the untimely death of Judge Reinhardt. He was replaced on the panel by Judge Susan Graber. The change made little difference
Tax Trials, published by Asbury Law Firm, focuses on litigation and judicial decisions involving tax law disputes. The blog covers appellate court rulings, particularly those from the Tax Court and federal circuit courts, addressing issues such as IRS regulations, administrative law principles, and tax deduction challenges. It also discusses IRS procedural updates, including filing deadlines and disclosure requirements related to syndicated conservation easements and micro-captive insurance companies. The content highlights significant cases impacting tax compliance, enforcement, and interpretation of tax statutes and regulations, providing insights into the legal reasoning behind court decisions and IRS administrative actions.
Yesterday the Tax Court issued a long-anticipated opinion on a fully-litigated micro-captive insurance company. Micro-captive insurance companies have long been a popular means of self-insuring for closely-held businesses but recently have come under additional scrutiny by the IRS. This…
On April 27, 2017, the IRS issued Notice 2017-29 which extended the deadline for disclosing certain participation in syndicated conservation easements.
On December 23, 2016, the IRS announced disclosure requirements for participants in syndicated conservation easements and substantially similar transactions…