The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from
Continue Reading Tax Court Issues Opinion Striking Down Captive Insurance Arrangement

As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships.  As a result, beginning January 1, 2018, partnerships
Continue Reading IRS Issues Guidance to Examiners Handling BBA Partnership Audits

Recently, a Colorado business protested the IRS’ disallowance of their business expenses.  The IRS alleges that the taxpayer was a Colorado medical marijuana dispensary to which Section 280E applies, as
Continue Reading Colorado District Court: IRS Enforcement of Section 280E Is Not A Criminal Investigation

In a strongly worded opinion that is very favorable for taxpayers who engage in sophisticated tax planning, the Sixth Circuit overturned a Tax Court opinion denying the benefits of a
Continue Reading Sixth Circuit Acknowledges Some Tax Laws Sanction Tax Avoidance