Tags » Tax Court

Section 79, captive insurance, 412i, 419, audits, problems and lawsuits

Taxpayers who previously adopted 419, 412i, captive insurance or Section 79 plans are in big trouble. In recent years, the IRS has identified many of these arrangements as abusive devices to funnel tax deductible dollars to shareholders and classified these arrangements as “listed transactions.” These plans were sold by insurance agents, financial planners, accountants and attorneys seeking large life insurance commissions. 694 more words

412i Plan

Docketed Cases. Hard Work (and a little luck!).

Our office has truly been blessed with good fortune over the past two weeks, both docketed cases before the United States Tax Court. The first came to us as a referral from a very talented estate planning attorney – a client having been audited resulting in a Revenue Agent’s Report reflecting $150,000 in additional tax and $30,000 in penalties. 652 more words

News

High Flying Attorney Gets His Wings Clipped by the IRS

T.C. Memo. 2015-1 Tulane Meredith Peterson v. Commissioner of Internal Revenue (Issued January 5, 2015)

The Story

Arcadia, California resident Tulane Peterson loved to fly. While licensed as an attorney since 1997, his first true and abiding love was flying; by the time of this court opinion he had been an amateur flyer for forty years. 818 more words

IRS

VAT zero rating

Introduction

This is an appeal to the Gauteng division of the Tax Court by the vendor for the determination of whether the services rendered by the vendor fell within the ambit of the zero rating for VAT in terms of section 11(2)(s) of the VAT Act. 14 more words

SARS

Expert’s Opinion Off Track in Appeal Near Train Station

A New Jersey Tax Court judge recently concluded that a plaintiff’s expert failed to make several adjustments which impacted the expert’s credibility with the court. The appeal involved a residential property located less than a mile from the train station in Summit, New Jersey. 334 more words

Court Decisions

Dept. of Homeland Securitas

By now, you may have already heard about the recent Tax Court decision regarding action taken by the IRS involving a Vermont captive owned by the Swedish security firm, Securitas. 335 more words

The Tax Court(!) in the New York Times. Plus Art.

Earlier this week, the New York Times ran a fairly breathless story about Susan Crile, an acclaimed artist, and the Tax Court’s decision regarding her problems with the IRS. 1,485 more words

Explainer