In 2015, I wrote a blog post with this same title (here) concluding that based on case law, a tax return that is given to a representative of the IRS is not considered filed and, therefore, the statute of limitations does not...
March Tax Decisions The Sixth Circuit holds that an IRS notice including certain employee-benefit plans with cash-value life insurance policies was invalid in Mann Constr., Inc. v. United States, No. 21-1500 (6th...
It is not every day that the Supreme Court hears a federal tax case. Of the issues the Court deals with, tax issues are usually low on the list. But the Court did hear a case earlier this year and on April 21, 2022 the Court...
In a February blog post, IRS Sends a Shot Across the Bow to Taxpayers With Grantor-Retained Annuity Trusts, I discussed the IRS blowing up a taxpayer’s GRAT planning and sending a message to taxpayers and tax...
In a recent memorandum decision, Clary Hood Inc. v. Commissioner, T.C. Memo. 2022-15, the Tax Court considered the issue of reasonable compensation to an owner/executive of a construction company. Unfortunately, the Tax...
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