The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them reportable transactions. A “listed transaction” is a transaction that is the same as or substantially similar to one of the types of transactions that the
On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the constitutionality and application of the so-called “Mandatory Repatriation Tax” [MRT] under Article I, §§8 and
In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its previous name of “Dukes”), making findings with regards to reasonable cause, valuation of personal goodwill, correct reporting of capital
By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS will send a Notice called a CP508C when a certification has been made. Despite this, many taxpayers are unaware of this potential consequence until they
The IRS recently issued a press release regarding its “continuous efforts to combat dubious Employee Retention Credit (ERC) claims” to announce an initial round of over 20,000 notification letters of disallowed ERC claims. This initial round of notices is addressing two “problem areas” the Service has identified in their ongoing review of ERC claims: 1)
There’s a hidden tax horror behind pass-through entities, cancellation of debt, and even prizes, winning, and awards: “phantom income.” It even sounds scary, right? And when it comes to one’s tax liability, it can be downright frightening indeed.
Phantom income usually refers to gain or profits that an entity reports, yet that the owner or
Ever thought about packing it all up and starting that romantic, expatriate life abroad? Ever felt like these parts were just so wild, it was time to find yourself a new passport? Expatriation, where a US citizen renounces citizenship, or where a legal permanent resident (LPR) renounces and terminates their status, is a very real
On remand for re-calculation of 4 errors in deficiency amounts, concerning years 2003, 2004, 2005, and 2006, the Tax Court entered final revised decisions based on the Commissioner’s twice-revised Rule 155 computations.
During the Larkins’ appeal, the Commissioner acknowledged four errors affecting the amounts of the deficiencies, additions to tax, and penalties. The court of
An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.”
In Pugh v. Commissioner, the IRS certified Pugh to the Secretary of State under I.R.C. § 7345 as an individual with a “seriously delinquent