Beginning today, March 15, 2022, anyone requesting a Certificate of No Tax Due from the Texas Comptroller must now use Form 86-114 Joint Request for Certificate of No Tax Due to make the request. This is a change from the...
The Supreme Court passes on most of the cases it is invited to decide, but appellate court splits are often the key to a Supreme Court opinion. Following the 5th Circuit Court of Appeals holding in...
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...
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