A former trial attorney for the IRS, Fox Rothschild Counsel Brian Bernhardt has a unique perspective to offer clients facing tax controversies and litigation. In a chat with Kristopher Flammang
Continue Reading Brian Bernhardt Featured on The Confident Retirement Podcast, Speaking about his Tax Controversy and Tax Litigation PracticeSpotlight on Fox Rothschild Tax Controversy Partner Ian Comisky
Ian M. Comisky was featured in the Bloomberg Tax article, “Spotlight on Tax Controversy Partner Ian Comisky.” View the full article.
Continue Reading Spotlight on Fox Rothschild Tax Controversy Partner Ian Comisky
Tax Court Holds that Supervisor Approval Requirement Does Not Apply to Penalties Determined by Computer Program
The Tax Court’s recent decision in Walquist v. Commissioner, 152 T.C. No. 3, further clarified the application of the supervisor approval requirement under section 6751(b)(1), which has been a
Continue Reading Tax Court Holds that Supervisor Approval Requirement Does Not Apply to Penalties Determined by Computer Program
Tenth Circuit: No Fifth Amendment Defense to the Application of Section 280E
I have written before about the battles being fought by cannabis businesses facing IRS examinations. IRS audits raise many issues for state legal cannabis businesses operating in violation of the
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Conservation Easements: A Year End Review
The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
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Only 2 Days Away – Fox Rothschild’s Second Annual Federal Tax Controversy Summit
Please join us for Fox Rothschild’s Second Annual Federal Tax Controversy Summit on December 12 in Philadelphia. We’ll be covering the latest developments in federal tax controversy and civil and
Continue Reading Only 2 Days Away – Fox Rothschild’s Second Annual Federal Tax Controversy Summit
Fox Rothschild’s Second Annual Federal Tax Controversy Summit
Please join us for Fox Rothschild’s Second Annual Federal Tax Controversy Summit on December 12 in Philadelphia. We’ll be covering the latest developments in federal tax controversy and civil and
Continue Reading Fox Rothschild’s Second Annual Federal Tax Controversy Summit
Section 280E Litigation Update: Harsh Results for Resellers
In the latest Tax Court opinion addressing the application of Section 280E to cannabis businesses there is no good news. However, there is some new guidance. In Patients Mutual Assistance
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IRS Provides Clarification for Business Taxpayers That Make Payments To State or Local Tax Credit Programs
We recently wrote on the new proposed regulations addressing the availability of charitable deductions when taxpayers receive or expect to receive corresponding state or local tax credits for contributions. The
Continue Reading IRS Provides Clarification for Business Taxpayers That Make Payments To State or Local Tax Credit Programs
U.S. Supreme Court Removes Tax Advantage for Online Retailers
In its 5-4 decision in South Dakota v. Wayfair, the U.S. Supreme Court gave states the authority to require online retailers to collect state sales taxes even if the
Continue Reading U.S. Supreme Court Removes Tax Advantage for Online Retailers