Have you ever committed to do something only to later discover that someone has already done it and done it very well? Well, I had one of those moments this week. Last week I wrote a blog post regarding the Taxpayer...
Late last year, the IRS made a big splash in tax news when it conceded the deductions of micro captive planning in a filed Tax Court case (Puglisi v. Commissioner, available here). Since that time there has been...
On January 12th, the IRS National Taxpayer Advocate delivered her annual report regarding the IRS to Congress. The report contains statistical information and recommendations for how the IRS could improve its service and how...
U.S. District Court upholds IRS motion for summary judgment on valuation of shares in family business for estate tax purposes in Connelly v. United States, 4:19-cv-01410-SRC (E.D. Mo. Sept. 21, 2021)....
In a recent memorandum opinion, Om P. Soni v. Commissioner, T.C. Memo 2021-137, the U.S. Tax Court discussed a rule rarely seen in tax cases: the “tacit consent rule.” The court held that although the taxpayer’s...
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