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OPINION by MICHAEL DONAHUE An open letter to fellow directors, general manager and district counsel: On Aug. 30, when I was out the country, during

Summary - A recent decision from the Ninth Circuit Court of Appeals illustrates the challenges faced by both bankrupt tenants and their landlords in the assumption of...

On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (“IRA” or the “Act”) into law. The IRA, which contains several energy-related tax credits and extends and...

These proposed regulations clarify issues that do not meet the definition of a federal tax controversy, exceptions to consideration by the IRS Office of Appeals IRS Appeals, and procedural and timing requirements that must be met before IRS Appeals will consider an issue.

Congress engaged in a flurry of legislative activity over the past month, enacting two bills that contain important tax provisions. On 9 August 2022…

Decisions from the Ninth and Eleventh Circuits departed from the Tax Court’s analysis of Chai v. Commissioner. In Laidlaw’s Harley Davidson Sales v. Commissioner, the Ninth Circuit applied a textualist approach and held approval is required only before assessment of penalty.

Louisiana Department of Revenue income tax auditors are increasingly proposing large assessments by misapplying a formula in a Department regulation…

Since Chai v. Commissioner, an opinion by the US Court of Appeals for the Second Circuit subsequently followed by the US Tax Court in several opinions, there has been a substantial...

One of the key principles in legislative drafting is consistency in language, including definitions. In looking at who is a business, there lacks the same

The IRS on Sept.