Tags » Tax Court

The Dos & Don'ts of Chapter 91 Requests

Every year motion practice heats up in the Tax Court with municipalities armed with “Chapter 91” motions.  As previously mentioned many times on this blog, … 760 more words

Court Decisions

Standard Practice Software Development: Hypercube Inc vs. Her Majesty The Queen

Hypercube Inc vs. Her Majesty The Queen demonstrates how the CRA apply standard practice or routine engineering to deny weak software development claims.

Analysis:

I’ve broken down the case by the  832 more words

SR&ED

Sewer Issues Make Tax Appeal a Messy Affair!

The New Jersey Tax Court recently tried a dispute between a property owner and a town that began in 2006.  In William G. Orpin, Jr. v. 1,015 more words

Court Decisions

New nomination for Tax Court judge

Friday, President Obama announced his nomination of Elizabeth Copeland, a partner at Strasburger & Price, as a judge on the United States Tax Court.  Elizabeth is very highly regarded within the tax community and will be an outstanding judge.   148 more words

ABA

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