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The U.S. government may have avoided a challenge to a controversial section 78 regulation by issuing the taxpayer a refund. In Kyocera, 1 the taxpayer challenged the validity of a regulation...
Taxpayers who are not parties to an action voiding an IRS Notice published without notice and comment should consider the risk of the IRS may nonetheless treat the Notice as valid as to nonparties. Federal courts held the IRS notices violate the Administrative Procedure Act.
Taxpayers who are not parties to an action voiding an IRS Notice published without notice and comment should carefully consider the risk that the IRS may nonetheless treat the Notice as...
IRS proposed regulations to identify syndicated conservation easement transactions as listed transactions. U.S. Tax Court held that Notice 2017-10, designated syndicated conservation easement transactions as listed transactions, was invalid and issued in violation of the APA.
Less than a month after the heavily followed Green Valley Investors, LLC, et al., decision, the IRS issued proposed regulations to identify certain syndicated conservation easement...