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...
It is not every day that the IRS agrees to pay a refund and the taxpayer declines. In Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.), one taxpayer did just that. At issue in Jarrett is whether the...
In a February 8th order in Hickory Equestrian LLC v. Commissioner, USTC No. 347-21, the U.S. Tax Court partially granted the IRS motion for summary judgment regarding the taxpayer’s $6.4 million easement deduction. The...
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