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May 16, 2023
The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain renewable energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). The...
April 27, 2023
US Tax Court issued opinion in Farhy v. Commissioner, holding that the Internal Revenue Service IRS lacked statutory authority to both assess tax penalties under Internal Revenue Code Section 6038b and collect said penalties via a levy against the taxpayer.
April 26, 2023
On April 3, 2023, the US Tax Court issued its opinion in Farhy v. Commissioner, holding that the Internal Revenue Service (IRS) lacked the statutory authority to both assess tax...
April 25, 2023
On April 4, the Internal Revenue Service issued Notice 2023-29 (the Notice), which describes certain rules the IRS intends to include in proposed regulations for qualifying for the energy community bonus production tax credit (PTC) rate and investment tax credit (ITC) amount under the Inflation Reduction Act of 2022 (IRA).
April 21, 2023
Internal Revenue Service Notice 2023-29 for qualifying for the energy community bonus production tax credit, rate and investment tax credit under the Inflation Reduction Act, IRS energy community bonus credit requirements taxpayers satisfy to qualify as energy community project
April 19, 2023
The IRS recently issued Proposed Regulations that clarify and update existing rules governing how and when forfeitures must be used in qualified defined contribution (e.g., 401(k)) and...
April 19, 2023
The U.S. Tax Court (USTC) on April 3, 2023, issued its opinion in Alon Farhy v. Commissioner, which held that the IRS lacks authority to assess certain foreign-related information...
April 12, 2023
In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the taxpayer failed...
April 7, 2023
The Inflation Reduction Act of 2022 (the “IRA”) added and modified certain renewable energy tax credit provisions of the U.S. Internal Revenue Code of 1986, as amended (the “Code”).[1]...
April 7, 2023
In a prior post, I discussed the dangers of playing Battleship with the IRS. Recently, taxpayers made a move and scored a hit with the Tax Court’s  recently issued decision in Alon...