Rare Taxpayer Victory in Case Involving the Strict Substantiation under Section 274(d).Nelson v. Commissioner, Docket no. 892-19 (no precedential effect). Of the four cases the Tax Court decided this...
An IRS legal memorandum involving a grantor-retained annuity trust (GRAT) released on December 30, 2021, should be a wake-up call to taxpayers and tax professionals. The memorandum blows up the taxpayer’s GRAT by...
On February 15, 2022, the IRS announced that it had changed its form (Form 14457) for making a voluntary disclosure with the IRS. We previously wrote about the IRS voluntary disclosure...
Josh O. Ungerman was quoted multiple times in the Feb. 15, 2022 article, “IRS Updates Voluntary Disclsoure Form with Electronic Bent,” in Tax Analysts 2022 by Nathan J. Richman. The article addresses the...
It is not every day that the IRS agrees to pay a refund and the taxpayer declines. In Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.), one taxpayer did just that. At issue in Jarrett is whether the...
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