Yesterday, the Tax Court issued its opinion in Alterman v. Commissioner, T.C. Memo 2018-83. This case involved the operation of a medical marijuana dispensary which was reported on Schedule
Continue Reading The High Tax Compliance Burden For Cannabis Businesses
General Tax Controversy News & Updates
IRS Guidance to Field: Deep Clean Equipment Used in Cannabis Businesses Before Selling
By Fox Rothschild LLP on
Attorneys representing cannabis businesses are often faced with questions about what happens when the cannabis business has not paid its taxes and the IRS is proceeding with collection actions. No…
Continue Reading IRS Guidance to Field: Deep Clean Equipment Used in Cannabis Businesses Before Selling
Conservation Easements: Charitable Deduction Disallowed Under “Substantial Benefits” Test
By Fox Rothschild LLP on
In Wendell Falls Development, LLC v. Commissioner, T.C. Memo. 2018-45, the Tax Court denied a charitable contribution deduction for a taxpayer’s contribution of a conservation easement because the taxpayer…
Continue Reading Conservation Easements: Charitable Deduction Disallowed Under “Substantial Benefits” Test
Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding
By Fox Rothschild LLP on
Recently, the written supervisory approval requirement of Section 6751(b) has been one of the primary issues in Tax Court litigation concerning penalties that the IRS has asserted against taxpayers. The…
Continue Reading Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding
District Court Holds Tax Liens Stay with Property after Conveyance
By Fox Rothschild LLP on
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…
Continue Reading District Court Holds Tax Liens Stay with Property after Conveyance
Changes for Individuals in New Federal Tax Law
By Fox Rothschild LLP on
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.
Continue Reading Changes for Individuals in New Federal Tax Law
Eleventh Circuit Holds Forfeited Deposit on Terminated Sale is Ordinary Income
By Fox Rothschild LLP on
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. …
Continue Reading Eleventh Circuit Holds Forfeited Deposit on Terminated Sale is Ordinary Income
Charles Rettig – From Private Practice to President Trump’s Nominee for IRS Commissioner
By Jessica Labella Kitain on
The White House released a statement on February 8, 2018 that President Trump nominated Charles Rettig as the new Commissioner of Internal Revenue Code for the remainder of a five…
Continue Reading Charles Rettig – From Private Practice to President Trump’s Nominee for IRS Commissioner
Tax Court Holds IRS Complied with Supervisor Approval Requirement
By Fox Rothschild LLP on
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…
Continue Reading Tax Court Holds IRS Complied with Supervisor Approval Requirement
Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized
By Fox Rothschild LLP on
We have all heard the old proverb “if it’s too good to be true, then it probably is.” In the tax world, this proverb might as well be referred to…
Continue Reading Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized