By Adam R. Young and Brian Bernhardt
On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency. In the CCM
Continue Reading IRS Cracks Down on Charitable Contributions of CryptocurrencyYesterday the Tax Court issued two decisions discussing the impact of Section 280E on cannabis businesses. One of these cases addresses the application of Section 280E to licensed and non-licensed
Continue Reading Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses
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
On January 30, 2017, Judge Goeke of the United States Tax Court issued an opinion rejecting a taxpayer’s asserted reasonable cause defense for failure to file Forms 5471, which are
Continue Reading Tax Court Rejects Taxpayer’s Reasonable Cause Defense for Failure to File Forms 5471