The IRS’s Mission is: “Provide America’s taxpayers top quality service by …
Texas Tax Roundup—October 2022: Rentals vs. Services, Drink Recipes, and More
The ALJ found that a taxpayer that was renting oilfield equipment and providing …
Plan Loan Offsets | What happens to a loan against a qualified retirement plan when the plan or employment is terminated?
A plan loan offset occurs when, pursuant to the plan loan terms, a participant’s benefit …
Tax Court in Brief | Cochran v. Comm’r | Tax Court Proceeding and Automatic Stay in Bankruptcy
Petitioners (husband and wife) filed a petition challenging a notice of …
Texas Tax Round Up (September 2022)
Hegar v. Tex. Westmoreland Coal Co., — In this case, the Texas Supreme Court denied the Comptroller’s …
Tax Court in Brief
Sandra Sander (“Petitioner”) established a trust—the Sandra E. Sander Lifetime Trust …
Dern Reminds that Settlement Language is Important in Section 104(a)(2) Physical Injury Cases
As a general matter, lawsuit recoveries are deemed fully taxable to the recipient …
Changes to Corporate Capital in Equity Financing Transactions, Part II.
In situations where corporations are needy for additional capital, existing and …
Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances
As background, U.S. Treasury regulations require that the ultimate parent entity …
Tax Court in Brief – Eze v. Commissioner
Petitioner Nnabugwu C. Eze reported income and expenses from two sets of activities …