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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.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.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.
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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New York Should Reevaluate Suspension of Driver's Licenses for Tax Collections
As this column has frequently highlighted, the New York Division of Taxation is not afraid to pursue aggressive positions in order to assess and collect revenue for the state. However, many taxpayers may be unaware of one of the more potent tools at the disposal of the division: the ability to suspend a taxpayer's driver's license for non-payment of substantial back taxes.Tax Court Addresses Real Estate Interest Deductions
The federal income tax treatment of interest deductions is often complex and unintuitive. A recent Tax Court case, Cardulla v. Commissioner, addressed a number of issues that may be relevant for taxpayers with interest expense on debt attributable to real estate activities.'Hyatt Hotels': Are Omissions From Gross Income an Accounting Method?
'Hyatt Hotels v. Commissioner' underscores that even an approach to accounting for income and expenses that has been applied consistently by a taxpayer over many years is not necessarily a "method of accounting" subject to the government's broad power to impose adjustments under Section 481(a).
Taxpayer Scores Major Victory in Franchise Tax Case
The 'Jefferies Group and Subsidiaries' case involved refund claims of over $10 million. While the Tax Division, among other challenges, objected to numerous positions taken on the corporate returns, the New York State Division of Tax Appeals rejected almost all claims made by the Tax Division.The Importance of Character: Tax Court Addresses Cancellation of Nonrecourse Debt
The distinction between COD income and gain on the sale of property was at issue in a recent Tax Court case, Parker v. Commissioner, discussed here.TRENDING STORIES
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