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An Uncharitable Regulation: Tax Court Invalidates Conservation Easement Regulation
In their Financing column, Ezra Dyckman and Charles Nelson discuss the recent Tax Court case, Valley Park Ranch, LLC v. Commissioner, which "is significant because it illustrates the Tax Court's willingness to invalidate a longstanding regulation based on procedural flaws that occurred almost 40 years ago."
Sham Stock Sales: 'Acqis Technology v. Commissioner'
'Acqis Technology v. Commissioner' confirms the continued vitality of the doctrine in the context of an apparent scheme to evade tax with respect to proceeds attributable to the settlement of patent infringement claims.
Tracking Generative AI: How Evolving AI Models Are Impacting Legal
A running compilation of how the legal landscape continues to be shaped by generative AI tools, from GPT technologies to art generation tools and beyond.Tax Court Order Raises Substance-Over-Form Questions
Whether an LLC is treated as a partnership or a disregarded entity for federal income tax purposes can sometimes have a significant effect on the tax consequences of a transaction. A recent order issued by the Tax Court in Joint Star Properties, LLC v. Commissioner illustrates the sorts of issues that can arise.Intercompany Loans Recharacterized: 'Fry v. Commissioner'
In 'Estate of Fry v. Commissioner', payments by one S corporation to another under identical ownership were recorded as intercompany loans. Following issuance of a notice of deficiency premised on the shareholder's stock basis in the debtor corporation being insufficient to support the losses claimed by him, the petitioners were ultimately successful in persuading the Tax Court that the transfers should be recharacterized as distributions by one corporation to its shareholder, coupled with contributions by that shareholder to the other corporation.
Law Journal Press | Digital Book
New Jersey Tax Handbook 2024
Authors: Robert F. Connolly, MST, Susan K. Dromsky-Reed, Jeffrey D. Gordon, Tiffany Wagner Donio, Frances B. Stella, Alysse Mcloughlin, Kathleen Quinn
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Here Comes the Sun: New Solar Tax Credit Rules Benefit Rental Property Owners
Ezra Dyckman and Charles Nelson discuss the Inflation Reduction Act, which has expanded the scope of green energy tax credits, and also proposed regulations by the Treasury Department that have the potential to allow even taxpayers with no income tax liability to more easily monetize some of these tax credits.Transferee Liability Under New York Law: 'Dillon Trust Co. v. United States'
Under some circumstances, sellers of stock of a corporation may be liable as transferees for corporate obligations arising before or in connection with the closing. In 'Dillon Trust Co. v. United States', the Court of Federal Claims concluded that the sellers of the stock of two corporations were liable for tax obligations of the corporations attributable to sales of assets for notes prior to the closing of the stock sale.