Add to ORKGIn Estate of McKelvey v. Commissioner, the Second Circuit Court of Appeals adopted the IRS’s position that probability analysis should be employed to determine that the taxpayer’s particular performance under the terms of a financial instrument was “virtually certain.” However, the IRS had steadfastly refused to promulgate regulations that, under a statutory delegation of authority to issue regulations to interpret and enforce the statute, could have administratively imposed that outcome
Several actions by Congress and the IRS aimed to reduce improper claims of the earned income tax cre...
In Bank of New York Mellon Corp. v. Commissioner, the Tax Court found that a structured trust advant...
The Internal Revenue Code is replete with policy preferences in the form of deductions, credits, and...
In Estate of McKelvey v. Commissioner, the Second Circuit Court of Appeals adopted the IRS’s positio...
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
When a taxpayer plans to undertake a transaction and its tax consequences are unclear, the taxpayer ...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...
From the early years of the federal income tax to the present, the Internal Revenue Service (IRS) ha...
Tax motivated transactions have become a serious consideration for Congress in recent years. The con...
During 1976, Congress placed some severe restrictions on tax shelter investments. In addition, even ...
The article focuses on the applicability of the standards of deference provided by the Chevron U.S.A...
In January, the Supreme Court will hear arguments in yet another tax case raising a question about t...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The validity of tax regulations has been challenged by taxpayers almost as long as there have been t...
In the late 1990\u27s and 2000\u27s, Merrill C. Roberts of Indiana ventured into horse racing. Event...
Several actions by Congress and the IRS aimed to reduce improper claims of the earned income tax cre...
In Bank of New York Mellon Corp. v. Commissioner, the Tax Court found that a structured trust advant...
The Internal Revenue Code is replete with policy preferences in the form of deductions, credits, and...
In Estate of McKelvey v. Commissioner, the Second Circuit Court of Appeals adopted the IRS’s positio...
In October, 2016, the Internal Revenue Service issued temporary and proposed regulations under Inter...
When a taxpayer plans to undertake a transaction and its tax consequences are unclear, the taxpayer ...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...
From the early years of the federal income tax to the present, the Internal Revenue Service (IRS) ha...
Tax motivated transactions have become a serious consideration for Congress in recent years. The con...
During 1976, Congress placed some severe restrictions on tax shelter investments. In addition, even ...
The article focuses on the applicability of the standards of deference provided by the Chevron U.S.A...
In January, the Supreme Court will hear arguments in yet another tax case raising a question about t...
Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietors...
The validity of tax regulations has been challenged by taxpayers almost as long as there have been t...
In the late 1990\u27s and 2000\u27s, Merrill C. Roberts of Indiana ventured into horse racing. Event...
Several actions by Congress and the IRS aimed to reduce improper claims of the earned income tax cre...
In Bank of New York Mellon Corp. v. Commissioner, the Tax Court found that a structured trust advant...
The Internal Revenue Code is replete with policy preferences in the form of deductions, credits, and...