The first part of Eaton’s closely watched U.S. Tax Court trial over the company’s financing of a 2012 acquisition has wrapped up, and the judge's questions to witnesses during the first two and a half weeks reveal that he’s leaning the government’s way on at least one of the central questions in the case. Here, Law360 offers five takeaways from the trial held Nov. 3-19, then resuming Dec. 4.
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5 Takeaways From Eaton Trial On Acquisition Financing, Part 1

By Molly Moses

The first part of Eaton’s closely watched U.S. Tax Court trial over the company’s financing of a 2012 acquisition has wrapped up, and the judge's questions to witnesses during the first two and a half weeks reveal that he’s leaning the government’s way on at least one of the central questions in the case. Here, Law360 offers five takeaways from the trial held Nov. 3-19, then resuming Dec. 4.

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Self-Employment Tax Applies To Partners, IRS Tells 1st Circ.

By Kat Lucero

An energy investment fund's limited partners are not exempt from self-employment tax, the IRS told the First Circuit on Wednesday, saying the partnership wrongly relied on state law to treat full-time partners as passive investors and exclude them from the levy.

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11th Circ. Urged To Restore Cut To $17M Easement Deduction

By Anna Scott Farrell

The Internal Revenue Service disregarded U.S. Supreme Court precedent in arguing that the U.S. Tax Court was right to slash a partnership's $17 million tax deduction for donating a conservation easement, the partnership told the Eleventh Circuit.

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LITIGATION

Split 6th Circ. Shields Baker Donelson, Not City Councilman

By Matt Perez

In a published opinion, the Sixth Circuit has found that Baker Donelson Bearman Caldwell & Berkowitz PC is shielded by qualified immunity as outside counsel for the city of Nashville in litigation over the law firm's firing of a city election commission chair and member of the firm.

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Investor Says Pot Co.'s Old Defenses Can't Stop Fraud Suit

By Mike Curley

An investor suing the principals of cannabis company Devi Holdings Inc. over an undisclosed $13 million tax liability is urging a Florida federal court to deny a motion for summary judgment from Devi's CEO, saying it ignores undisputed facts and rehashes old arguments that were rejected at the dismissal stage.

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REGULATION

IRS To Ax Tax Preparer Regs Decade After DC Circ. Injunction

By Kat Lucero

The Internal Revenue Service will withdraw long-dormant proposed regulations for independent tax return preparers, which the D.C. Circuit effectively halted the agency from finalizing in 2014, the IRS announced Wednesday.

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LAW FIRMS IN TODAY'S NEWS

Baker Donelson

Chamberlain Hrdlicka

Clark Hill

Greenberg Traurig

Holland & Knight

Latham & Watkins

Shook Hardy

Skadden Arps

Venable LLP

White and Williams

COMPANIES IN TODAY'S NEWS

Ankura Consulting Group LLC

Citigroup Inc.

Cooper Industries PLC

Denham Capital Management LP

Eaton Corp. PLC

Getty Images Holdings Inc.

Morgan Stanley

S&P Global Inc.

GOVERNMENT AGENCIES IN TODAY'S NEWS

Internal Revenue Service

Metropolitan Government of Nashville and Davidson County

Social Security Administration

U.S. Court of Appeals for the Eleventh Circuit

U.S. Court of Appeals for the First Circuit

U.S. Court of Appeals for the Sixth Circuit

U.S. Department of Justice

U.S. Department of the Treasury

U.S. District Court for the Southern District of Florida

U.S. Supreme Court

U.S. Tax Court