Modifying the terms of indebtedness, as opposed to cancelling or discharging the indebtedness, leaves the indebtedness outstanding but revises the terms governing the obligation. For example, the lender and borrower of a debt...
Just when you thought the IRS hit full speed in its enforcement campaign against microcaptives, the IRS found another gear. After pursuing captive management companies, tax advisors, and taxpayers alike, the IRS has set...
On June 17th, U.S. Tax Court Judge Tamara Ashford issued an opinion in Leticia C. Santos v. Commissioner holding for a taxpayer on a worker classification case. We have previously discussed how the IRS usually...
In a previous blog post we discussed the Tax Court’s recent decision in The Estate of Howard V. Moore v. Commissioner. An important take away from Moore for tax professionals and their clients is...
If Tax Court Judge Lauber’s June 15, 2020 order is any indication, the Tax Court has grown tired of syndicated conservation easement cases. The case is Coal Property Holdings, LLC v. Commissioner, Tax Court Docket No....
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