Just when you thought the IRS hit full speed in its enforcement campaign against microcaptives, the IRS found another gear. After pursuing captive management companies, tax advisors, and taxpayers alike, the IRS has set...
Category: Blog
Tax Court Hands a Taxpayer a Rare Win in a Worker Classification Case
On June 17th, U.S. Tax Court Judge Tamara Ashford issued an opinion in Leticia C. Santos v. Commissioner holding for a taxpayer on a worker classification case. We have previously discussed how the IRS usually...
Stress Testing the Estate Plan
In a previous blog post we discussed the Tax Court’s recent decision in The Estate of Howard V. Moore v. Commissioner. An important take away from Moore for tax professionals and their clients is...
If Tax Court Judge Lauber’s June 15, 2020 order is any indication, the Tax Court has grown tired of syndicated conservation easement cases. The case is Coal Property Holdings, LLC v. Commissioner, Tax Court Docket No....
Debt Relief: Breaking Down the Tax Aspects of Covid-19’s Economic Impact – Part III, Defining Indebtedness
Indebtedness has been a central focus of Parts I and II of this series, and it will continue to be a key concept in future posts as we explore in further detail the COD Income exceptions and discuss...