As part of its continuing guidance to taxpayers and practitioners about how its resumption of activities following the government shutdown is impacting pending matters, the Internal Revenue Service has published
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Tax Controversy Litigation
United States Tax Court Will Reopen on January 28, 2019
According to a notice posted on its website over the weekend, the United States Tax Court will reopen for business and resume full operations tomorrow morning, January 28, 2019. The…
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IRS Publishes FAQs Addressing Status of Tax Court Cases In Light of Government Shutdown
On December 28, 2018, at 11:59 p.m., the United States Tax Court closed its doors in light of the federal government shutdown, and has not reopened for business since then.
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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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Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses
Yesterday 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…
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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 in the Offing? Marinello Limits Tax Obstruction Prosecutions
Ian M. Comisky and Matthew D. Lee have authored a Journal of Taxation article entitled “IRS in the Offing? Marinello Limits Tax Obstruction Prosecutions.” In their article, Ian and Matt…
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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…
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Section 280E and the Harsh Reality of Double Taxation
There is not too much to say about the Tax Court’s latest decision involving a marijuana company. In Loughman v. Commissioner, T.C. Memo 2018-85, the operators of a Colorado…
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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…
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