Earlier this year, I wrote about Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.), a case in which a crypto taxpayer rejected a complete government concession of a lawsuit. At issue in the case was whether...
Category: Blog
Part Two: Are Tax Returns Given to an IRS Agent Considered Filed?
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 Blog
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...
Some CRATs are CR*P, So Sayeth the IRS and Department of Justice
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...