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Delaware Must Turnover Communications with Microcaptive Promoters
By on April 26, 2023
On April 21st, a Third Circuit Court of Appeals panel ruled that the Delaware Department of Insurance (DDOI) must comply with a 2020 summons from the IRS for all communications with microcaptive insurance companies and their managers. This is another step in the IRS continuing attack on microcaptive insurance companies.
Update on IRS Tax Deposits and a Potential Crack in the Door for Interest Abatement?
By on April 20, 2023
I recently wrote a blog about whether partners in BBA partnerships can make deposits under IRC Section 6603. Now there are more updates to share about deposits, although this time unrelated (at least directly) to BBA partnerships.
Tax Court Opinion Reminds Taxpayers to be Careful about Social Media Posts
By on April 14, 2023
Most lawyers, especially those who handle some type of litigation, have warned clients about social media posts. Because people like to post pictures of events, extravagant trips and other adventures or discuss what they are doing on social media, it is standard operating procedure for lawyers to search social media of an opposing party for helpful information.
By on April 6, 2023
On April 3rd the Tax Court issued an opinion in Farhy v. Commissioner, holding that the IRS does not have authority to assess certain international information return reporting penalties. As a result, any taxpayer who previously paid an international information return penalty should consider requesting a refund of the penalty.
1014 Basis Adjustments and Irrevocable Grantor Trusts
By on Aprl 3, 2023
On April 17, 2023, the IRS released Revenue Ruling 2023-02, concluding that the basis adjustment incident to a person's death, under Section 1014 of the Code, generally does not apply to the assets of a grantor trust unless the assets are included in the grantor's gross taxable estate.