On December 3, 2024, the US District Court for the Eastern District of Texas found that the Corporat...
Treasury and Internal Revenue Service Crack Down on Related-Party Basis Shifting
In June of 2024, the Internal Revenue Service (IRS) issued guidance attempting to address the percei...
Internal Revenue Service Plans Dozens of Corporate Jet Audits
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of ...
Two Easements Conserved But Not in Perpetuity
In February of 2020, the United States Tax Court issued a Memo, Railroad Holdings, LLC T.C. Memo. 20...
The Challenges for Art Donation (Part 3 of 3): Trouble with $0 Donations
When it comes to the charitable donation of art, the Internal Revenue Service (IRS) has increasingly...
The Challenges for Art Donation (Part 2 of 3): Economic Substance
As discussed in part one of this series on art donations, a taxpayer who wishes to receive a tax ded...
The Challenges for Art Donation (Part 1 of 3): An Introduction
Among the many ways that Congress uses tax laws to influence taxpayers’ spending, encouraging dona...
Government Transparency: Commissioner of Revenue to be Bound by Tax Court Decisions
On April 2, 2024, Senate File (SF) 4742, as a companion to House File (HF) 4934, was subject to a he...
Government Transparency: Commissioner of Revenue to be Bound by Court Decisions
On Thursday, March 21, 2024, the Minnesota Senate Tax Committee had a hearing regarding Chair Ann Re...
Employee Retention Credit Voluntary Disclosure Program Ends March 22, 2024
The Employee Retention Credit (ERC) is a refundable tax credit for certain eligible business and tax...
Anticipating Tax Litigators…And the IRS (Part 2 of 2): Tax Strategy Tips
Since the COVID-19 pandemic, the Internal Revenue Service (IRS) has had a long backlog that, due in ...
Anticipating Tax Litigation… And the IRS (Part 1 of 2): Tax Filing and Maintenance Tips
Despite the relative rarity of an individual taxpayer’s file being brought to United States Tax Co...
When Winning Isn’t “Prevailing”: Success in Bankruptcy Court Does Not Translate to Attorneys’ Fees
In June 2016, William Canada, Jr. took the Internal Revenue Service (IRS) to bankruptcy court and wo...
IRS Acted “Against Equity or Good Conscience” to Deny Hardship Due to Depression
On April 20, 2017, the United States Tax Court (Court) held in favor the petitioners, John C. Trimme...
What’s in a Name?: The ABA Attempts to Define “Cryptocurrency”
Until relatively recently, the number of individuals who bought and sold cryptocurrencies (crypto) a...
Is The IRS Going to the Moon?: President Biden’s Executive Order on Digital Assets
On March 9, 2022, President Biden signed an executive order setting out his administration’s strat...
Split In The 5th Circuit Muddies The FBAR Waters
There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (...
Three Things – Ask A Tax Attorney
Recently, I wrote an article for the Hennepin County Lawyer addressing some of the kinds of tax ques...
Tax Questions Every Solo And Small Firm Lawyer Should Be Able To Answer
Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen...
IRS Issues Guidance Regarding Levy Actions Involving Restaurant Revitalization Fund
The American Rescue Plan Act established the Restaurant Revitalization Fund (RRF) to provide support...