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
General Tax Controversy News & Updates
An Update on Litigation of Cannabis Business Tax Issues
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
The High Tax Compliance Burden For Cannabis Businesses
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
IRS Guidance to Field: Deep Clean Equipment Used in Cannabis Businesses Before Selling
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
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
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
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
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
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
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