Texas Courts and The Doctrine of Res Judicata
The doctrine of res judicata, or claim preclusion, bars a second action by parties and those in privity with them on matters actually litigated in a previous suit, as well as claims that could
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Tax Court in Brief | Genecure, LLC v. Commissioner | Capital Expenses, QTDP Recapture Tax, Fraud-Related Penalty Requirements
The Tax Court in Brief – May 23rd – May 27th, 2022
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
For a link to…
Tax Court in Brief | Albrecht v. Commissioner | Charitable Contributions and Contemporaneous Written Acknowledgements
The Tax Court in Brief – May 23rd – May 27th, 2022
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
For a link to…
Exempt Payments to Non-Resident Aliens and Federal Withholding
Exempt Payments to Non-Resident Aliens and Federal Withholding
Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to non-resident aliens are generally subject to reporting requirements…
Tax Exemption and Unrelated Business Income Tax (UBIT): Rules, Modifications and Exceptions (Part 2 of 3)
This Insights blog is Part 2 of a 3-Part series focused on the unrelated business income tax rules for the nonprofit organization that is tax-exempt pursuant to section 501(c)(3) of the Internal Revenue Code (the “Code”).
Part 1—Tax Exemption…
Dischargeability of Divorce-Related Debts
Subsection (15) of Section 523(a) was added to the Bankruptcy Code in the Bankruptcy Reform Act of 1994 to expand the Section 523(a)(5) exception to discharge for marital debts. Section 523(a)(15) provides that an individual is not discharged from any…
You Received an IRS Notice CP2000, Now What?
You might receive an IRS Notice CP2000 (“CP2000”) in the mail. The IRS issues these particular notices to taxpayers based on discrepancies between tax return reporting and third-party reporting. Taxpayers must pay attention to these notices, as well as others,…
IRS Tax Penalties and the Tax Professional Reliance Defense
IRS Tax Penalties and the Tax Professional Reliance Defense
No one wants to pay federal taxes. And this truism applies more so with respect to federal tax penalties. Accordingly, clients often call upon their tax professionals to request waiver or…
Are commissions owed post-termination of employment or engagement? The Procuring-Cause Doctrine Revisited
In 1916, the Texas Supreme Court articulated the procuring-cause doctrine, which is a default rule that applies when a valid agreement to pay a commission on sales of property or product does not address whether commissions are owed on sales…
Texas Tax Roundup—April 2022
Hiya folks, and welcome back to another gripping installment of the Texas Tax Roundup. So, let’s ditch the small talk and get started!
Court Cases
Sales Tax
Hegar v. RTU, Inc., No. 22-0098 (Apr. 29, 2022)—The Texas Supreme Court…