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Tax Court Sides With IRS In Mislabeled IRA Payments Row

Law360, New York (June 29, 2015, 8:24 PM EDT) -- The U.S. Tax Court handed the Internal Revenue Service a win in a dispute over alleged domestic international sales corporation commission payments on Monday, finding the parent of a group of manufacturing companies liable for tax deficiencies because the payments were essentially shareholder dividends followed by IRA contributions.

In granting the IRS' bid for partial summary judgment, Judge Kathleen Kerrigan rejected arguments from Ohio-based Summa Holdings Inc. and its subsidiaries that it properly made millions in payments in 2008 to JC Export Inc., a tax-exempt entity formed as an interest charge DISC, a structure traditionally used by exporters for tax savings....

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Kirkland & Ellis LLP has redefined what it means to be the biggest of BigLaw — weighing in at 2,116 attorneys by year end 2018 and becoming the first firm since Law360 began tracking law firm head counts to top 2,000 U.S.-based attorneys.

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