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Two courts address tax shelter exception to tax practitioner privilege.

The Tax Court and the Seventh Circuit recently decided cases dealing with the tax practitioner/client privilege under Sec. 7525. The Tax Court...
Tax Adviser, The, 08/01/09 by Beavers, James · More from publication
Ninth Circuit awards litigation costs paid by third party.

[ILLUSTRATION OMITTED] The Ninth Circuit reversed the Tax Court and held that a taxpayer could "incur" attorneys' fees initially paid by a...
Tax Adviser, The, 08/01/09 by Beavers, James · More from publication
Limitation period for equitable innocent spouse relief held invalid.

[ILLUSTRATION OMITTED] In a decision of the full court, the Tax Court held that Regs. Sec. 1.6015-5(b) (1), which imposes a two-year...
Tax Adviser, The, 06/01/09 by Beavers, James · More from publication
Circular like-kind exchange disallowed.

The Tax Court disallowed tax-free treatment for a like-kind exchange transaction in which the taxpayer exchanged properties with a related...
Tax Adviser, The, 06/01/09 by Beavers, James · More from publication
IRS issues guidance on losses from Ponzi schemes.

[ILLUSTRATION OMITTED] The IRS has released guidance on how investors who have fraud losses from a Ponzi scheme should treat their losses for...
Tax Adviser, The, 05/01/09 by Beavers, James · More from publication
Securities transfer is not a securities lending arrangement.

In a case of first impression, the Tax Court held that a billion dollar--plus securities transaction was not a securities lending arrangement...
Tax Adviser, The, 05/01/09 by Beavers, James · More from publication

IRS issues final regulations on Sec. 6694 tax return preparer penalties.

[ILLUSTRATION OMITTED] The IRS issued final regulations implementing the changes to the Sec. 6694 tax return preparer penalties made by the...
Tax Adviser, The, 02/01/09 by Beavers, James · More from publication
IRS issues guidance on determining wagering gains and losses.

The Office of Chief Counsel issued a memorandum explaining how to determine the wagering gains and losses of casual gamblers. Scenario ...
Tax Adviser, The, 02/01/09 by Beavers, James · More from publication
IRS identifies sale of charitable remainder trust interests as a transaction of interest.

[ILLUSTRATION OMITTED] In a notice, the IRS has identified as transactions of interest certain transactions in which a sale or other...
Tax Adviser, The, 01/01/09 by Beavers, James · More from publication
Wrongful levy judgment treated as overpayment of tax.

The Ninth Circuit held that for purposes of calculating the overpayment interest rate on a wrongful levy judgment, the judgment should be treated...
Tax Adviser, The, 01/01/09 by Beavers, James · More from publication

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Article Results (Showing 1 - 10 of 26) RSS Alert

Two courts address tax shelter exception to tax practitioner privilege.

Ninth Circuit awards litigation costs paid by third party.

Limitation period for equitable innocent spouse relief held invalid.

Circular like-kind exchange disallowed.

IRS issues guidance on losses from Ponzi schemes.

Securities transfer is not a securities lending arrangement.

IRS issues final regulations on Sec. 6694 tax return preparer penalties.

IRS issues guidance on determining wagering gains and losses.

IRS identifies sale of charitable remainder trust interests as a transaction of interest.

Wrongful levy judgment treated as overpayment of tax.

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