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Expert Analysis

Self-Help Not The Preferred Way To Address Tax Conflicts

Law360, New York (November 26, 2014, 11:04 AM EST) -- On Oct. 30, the U.S. Tax Court ruled that a key executive of a technology company acquired by Google for $93 million was required to report a large portion of his merger consideration as ordinary compensation income. Perhaps even more than the substantive tax principle it stands for, the case is a reminder that self-help is not the preferred way of addressing disagreements between taxpayers and employers regarding tax reporting positions. The salient facts of the case, Brinkley v. Commissioner,[1] as well as its key takeaways, are summarized below....

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