Page 2 - Mann Construction News Today

Today's guest post is from Jonathan Black, a senior associate in the Washington DC office of Caplin & Drysdale. Jon discusses the IRS's latest efforts to address conservation...

On Dec. 6, 2022, the IRS issued proposed regulations identifying syndicated conservation easement transactions as listed transactions for purposes of I.R.C. § 6011.

Freeman Law is, and for years has been heavily involved in advising on and defense of conservation easement charitable contributions authorized under section 170, Title 26 of the Internal...

On December 6th, the IRS proposed regulations (and comment period for same) that would require participants and promoters of syndicated conservation easement transactions to make...

Following defeat in Tax Court cases of Administrative Procedure Act, IRS issues proposed regulations identifying syndicated conservation easement transactions as listed transactions. This shows the IRS is taking a proactive approach in addressing the APA challenges.

On December 6, 2022, less than a month after its historic loss in the Tax Court in Green Valley Investors LLC v. Commissioner, 159 T.C. 5 (2022), the IRS released Announcement 2022-28...

The service is reacting to recent court decisions challenging its ability to classify the investments as abusive schemes.

The taxpayers contended the guidance required pre-promulgation notice and comment.

In Mayo Found. for Med. Educ. & Rsch. v. United States, 131 S.Ct. 704 (2011), the Supreme Court of the United States made clear that administrative law rules apply to tax guidance like...

On March 21, 2022, the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act (APA) and granted broad injunctive relief requiring the IRS to return to taxpayers and material advisors the documents and information obtained improperly under the Notice.