United States v. Gerard, a recent case from the Northern District of Indiana, demonstrates how a tax lien, once attached, can stay with property even after the property is
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U.S. Senators Ask Supreme Court to Overturn Quill
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A number of parties have filed amicus curiae briefs in South Dakota v. Wayfair, a case that could substantially reshape the state sales tax landscape. See here. Perhaps…
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New Jersey Announces Possibility of Tax Amnesty
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The New Jersey legislature may enact a law that would create a tax amnesty program for New Jersey taxes. If enacted, the amnesty program would not exceed 45 days or…
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Changes for Individuals in New Federal Tax Law
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The Tax Cuts and Jobs Act, enacted in December 2017, is the most significant change to the U.S. Tax Code since 1986 and dramatically alters the tax landscape for individuals.
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Eleventh Circuit Holds Forfeited Deposit on Terminated Sale is Ordinary Income
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In CRI-Leslie, LLC, the Eleventh Circuit confronted whether a taxpayer is entitled to capital gains treatment for a forfeited deposit on the sale of land. CRI-Leslie, LLC, Donald W. …
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U.S. Supreme Court Schedules Oral Arguments in South Dakota v. Wayfair
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The U.S. Supreme Court has scheduled oral arguments for April 17 in South Dakota v. Wayfair, a case that could dramatically reshape the sales tax landscape for online retailers. …
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Tax Court Reopens Record to Admit Penalty-Approval Forms
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In Rajagopalan v. Commissioner, Judge Holmes confronted what he called the Chai ghoul. See Rajagopalan v. Commissioner, Docket No. 21394-11, Order, Dec. 20, 2017. In Chai v. Commissioner…
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Eleventh Circuit Cuts into Presumption of Correctness Standard for IRS Assessments
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In United States v. Stein, the Eleventh Circuit recently decided a novel – but critical – issue for taxpayers. It held that an affidavit that satisfies Rule 56 of…
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Supreme Court to Decide How Sales Taxes Apply to Online Retail Activity
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The Supreme Court recently granted certiorari in South Dakota v. Wayfair Inc., a case that could dramatically change how sales taxes apply to online retail activity. Under the Supreme…
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Tax Court Holds IRS Complied with Supervisor Approval Requirement
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The Tax Court’s recent opinion in Roth v. Commissioner, T.C. Memo. 2017-248, raises interesting issues about the need for supervisor approval when the IRS asserts penalties. In 2007, the…
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