Anyone who makes a taxable gift (more than $17,000 in 2023, $18,000 in 2024) in a taxable year must file a Form 709, United States Gift Tax Return, reporting the gift to the IRS. Generally, the IRS then has three years to...
The Tax Court recently called into question whether a partner designated as a limited partner is truly a limited partner. In Soroban Capital Partners, LP v. Commissioner, the court analyzed whether a partner was truly a...
On October 26th, the Tax Court issued an interesting opinion in Mill Road 36 Henry LLC v. Commissioner, T.C. Memo 2023-129, upholding the IRS disallowance of a $8.9 million deduction for an easement donation but also holding...
I’ve previously written blog posts regarding the IRC Section 6651 failure-to-file penalty and its application to electronically filed tax returns. On October 24th, the 11th Circuit Court of Appeals issued a decision...
The IRS has recently increased their focus and examinations of businesses who deal in cash (or cash equivalents such as cashier’s checks and money orders). These examinations have led to significant fines and penalties for...
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