General Tax Controversy News & Updates

I have recently penned a Law360 article discussing lessons learned from recent tax decisions impacting cannabis businesses.  We will continue to cover this topic on this blog.

To be alerted…
Continue Reading An Update on Litigation of Cannabis Business Tax Issues

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

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

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

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

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