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Lee Sheppard Takes on Container Corp.
By Jonathan Prokup In her column last Monday, Lee Sheppard criticized Judge Holmes of the Tax Court for, as she put it, “strain[ing] to find a reason to hold for the taxpayer” in the recent case of...
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A Four-Letter Word Causes The IRS Trouble
By Buck Buchanan Last summer, the Ninth Circuit Court of Appeals handed the IRS a defeat that the IRS did not take lightly. The Ninth Circuit ruled that an overstated basis, no matter how large, is...
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Deconstructing Canal Corp. v. Commissioner – Part I
By Jonathan Prokup and Dustin Covello Many practitioners were taken aback by the recent Tax Court decision in Canal Corp. v. Commissioner, where Judge Kroupa issued a stinging opinion that not only...
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As the World Turns: Court Rebuffs Novel Spin on International Tax Filing Rules
By Hale Sheppard For better or worse, many a tax dispute has been won or lost on procedure, often on the question of whether a document – be it a tax return, refund claim, or petition – was timely...
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Tax Court May Be The Forum Of Choice For Taxpayers Seeking To Challenge...
By Dustin Covello & Phil Karter As Tax Blawg readers know, after the Supreme Court’s Mayo decision adopted the deferential Chevron standard for determining the validity of Treasury regulations...
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Always Say Never: Does Financial Distress Create Reasonable Cause Sufficient...
By Hale Sheppard Nearly all taxpayers will face penalties by the IRS at some point, regardless of their sophistication level and size. Accordingly, tax practitioners, even those who claim not to get...
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If You’re On Call, You’re Out of Luck in Passive Activity Cases
By Hale Sheppard Back in the era of beepers, being “on call” evoked imagery of importance. Indeed, those people required by their job to carry a beeper, along with those who did so voluntary,...
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The Parameters of Qualified Amended Returns Examined by Tax Court in Case of...
By Hale Sheppard Life grants few chances at true redemption. The Internal Revenue Code, likewise, is not known for facilitating taxpayer salvation. Sure, under certain circumstances, taxpayers have an...
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Before You Abandon That Underwater House, Read This!
By George W. Connelly The Tax Court recently issued a Summary Opinion, Malonzo v. Commissioner of Internal Revenue, T.C. Summ. Op. 2013-47, involving an individual who was underwater on her mortgage,...
View ArticleLee Sheppard Takes on Container Corp.
In her column last Monday, Lee Sheppard criticized Judge Holmes of the Tax Court for, as she put it, “strain[ing] to find a reason to hold for the taxpayer” in the recent case of Container Corp. v....
View ArticleA Four-Letter Word Causes The IRS Trouble
Last summer, the Ninth Circuit Court of Appeals handed the IRS a defeat that the IRS did not take lightly. The Ninth Circuit ruled that an overstated basis, no matter how large, is simply not omitted...
View ArticleDeconstructing Canal Corp. v. Commissioner - Part I
Many practitioners were taken aback by the recent Tax Court decision in Canal Corp. v. Commissioner, where Judge Kroupa issued a stinging opinion that not only recast a leveraged partnership...
View ArticleAs the World Turns: Court Rebuffs Novel Spin on International Tax Filing Rules
For better or worse, many a tax dispute has been won or lost on procedure, often on the question of whether a document - be it a tax return, refund claim, or petition - was timely filed. The...
View ArticleTax Court May Be The Forum Of Choice For Taxpayers Seeking To Challenge...
As Tax Blawg readers know, after the Supreme Court’s Mayo decision adopted the deferential Chevron standard for determining the validity of Treasury regulations (instead of the less deferential...
View ArticleAlways Say Never: Does Financial Distress Create Reasonable Cause Sufficient...
Nearly all taxpayers will face penalties by the IRS at some point, regardless of their sophistication level and size. Accordingly, tax practitioners, even those who claim not to get involved in...
View ArticleIf You're On Call, You're Out of Luck in Passive Activity Cases
Back in the era of beepers, being "on call" evoked imagery of importance. Indeed, those people required by their job to carry a beeper, along with those who did so voluntary, displayed the devices...
View ArticleThe Parameters of Qualified Amended Returns Examined by Tax Court in Case of...
Life grants few chances at true redemption. The Internal Revenue Code, likewise, is not known for facilitating taxpayer salvation. Sure, under certain circumstances, taxpayers have an opportunity to...
View ArticleBefore You Abandon That Underwater House, Read This!
The Tax Court recently issued a Summary Opinion, Malonzo v. Commissioner of Internal Revenue, T.C. Summ. Op. 2013-47, involving an individual who was underwater on her mortgage, and who abandoned the...
View ArticleTax Court Allows Do-Over In Structuring Transaction
Wish you had planned your transaction differently for tax purposes? In limited circumstances, the courts may allow a taxpayer to claim tax consequences consistent with a transaction’s economic...
View ArticleCan the Tax Court dodge jurisdiction...again?
The undersigned has been practicing in the United States Tax Court since May 1971, and has seen many changes, such as the evolution of the very simple Tax Court Rules of Practice during 1973 into the...
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