Tax Controversy Litigation

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

In United States v. Stein, the Eleventh Circuit recently decided a novel – but critical – issue for taxpayers.  It held that an affidavit that satisfies Rule 56 of
Continue Reading Eleventh Circuit Cuts into Presumption of Correctness Standard for IRS Assessments