In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance
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The Taxpayer Assistance and Service Act: Title III: Judicial Review
This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…
Continue Reading The Taxpayer Assistance and Service Act: Title III: Judicial ReviewPartnership Interest Sale Inventory Gain is Not U.S. Source Income
By Adam Young on
On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner…
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By Fox Rothschild LLP on
In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties. …
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Tax Court Holds IRS Complied with Supervisor Approval Requirement
By Fox Rothschild LLP on
The Tax Court’s recent opinion in Roth v. Commissioner, T.C. Memo. 2017-248, raises interesting issues about the need for supervisor approval when the IRS asserts penalties. In 2007, the…
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Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
By Fox Rothschild LLP on
The issue before the Tax Court in Huzella v. Commissioner, T.C. Memo. 2017-210, centered around a coin business on eBay, and whether the petitioner, Thomas Huzella, could substantiate his…
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Tax Court Denies Treaty Benefit to Canadian Post–Doctoral Fellow
By Fox Rothschild LLP on
In a case of first impression, the Tax Court held that the U.S.–Canada Tax Treaty (Treaty) did not exempt a Canadian citizen from U.S. income tax on the unemployment compensation…
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Tax Court Broadens Foreign Earned Income Exclusion
By Fox Rothschild LLP on
The Tax Court’s recent decision in Linde v. Commissioner, T.C. Memo. 2017-180, brought good news to taxpayers working outside the United States. In Linde, the Tax Court held…
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