U.S. District Court upholds IRS motion for summary judgment on valuation of shares in family business for estate tax purposes in Connelly v. United States, 4:19-cv-01410-SRC (E.D. Mo. Sept. 21, 2021)....
In a recent memorandum opinion, Om P. Soni v. Commissioner, T.C. Memo 2021-137, the U.S. Tax Court discussed a rule rarely seen in tax cases: the “tacit consent rule.” The court held that although the taxpayer’s...
The U.S. Tax Court recently issued two memorandum opinions regarding animal breeding activities and whether the taxpayers at issue could deduct expenses in excess of income from the activity. In Skolnick v. Commissioner,...
The IRS recently issued Notice 2021-65, offering guidance to employer-taxpayers after the Infrastructure Investment and Jobs Act (“Infrastructure Act”) ended the employee retention credit for...
Taxpayer allowed to deduct alimony payments through his Section 125 cafeteria plan per Tax Court decision in Charles H. Leyh v. Commissioner, 157 T.C. No. 7 (Oct. 4, 2021). In a case of first impression, the Tax Court held...
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