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...
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...
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