Federal
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June 05, 2024
IRS Presses Justices To Weigh In On Tax Challenge Deadline
The IRS urged the U.S. Supreme Court to overturn a Third Circuit decision finding the U.S. Tax Court's 90-day deadline for challenging tax bills is not set in stone, arguing the couple defending the ruling are wrongly relying on a 2022 high court decision.
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June 05, 2024
Billionaire's 'Naive' Stock-Trading Pilot Asks For No Prison
A private pilot for U.K. billionaire Joe Lewis is asking for no prison time after pleading guilty to insider trading on stock tips provided by his boss, arguing that he has otherwise lived a law-abiding life and is less culpable than many white-collar defendants who've come through the Manhattan federal court.
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June 05, 2024
Taxpayer Advocacy Committee Meeting Moved Up
The Internal Revenue Service moved up an open meeting of the Taxpayer Advocacy Panel's Notices and Correspondence Project Committee to June 18, it said Wednesday.
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June 04, 2024
Full DC Circ. Asked To Weigh Foreign Info Disclosure Penalties
A D.C. Circuit panel made questionable assumptions about congressional intent when it revived the IRS' authority to assess and administratively collect penalties related to undisclosed foreign corporations, a businessman said Tuesday in asking the full appellate court to hear his case.
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June 04, 2024
Sen. Leaders Press Biden's Tax Court Nominees On Fairness
Senate Finance Committee leaders pressed President Joe Biden's three new judicial nominees for the U.S. Tax Court to explain Tuesday how they would extend fair treatment to taxpayers if they are confirmed.
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June 04, 2024
Aflac Matriarch's Estate Owes $1.9M Penalty, Tax Court Told
The Internal Revenue Service is seeking an additional accuracy penalty of over $1.9 million from the estate of the matriarch of the family that founded Aflac, according to a filing in the U.S. Tax Court.
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June 04, 2024
Tax Law Firm Can't Kick Ex-Clients' Class Suit To Arbitration
Former clients of a Florida-based tax law firm who live in Wisconsin can move forward with their proposed class action accusing the firm of malpractice and charging illegal fees, a Wisconsin federal judge ruled Tuesday, rejecting the firm's requests to toss the suit or move it to arbitration.
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June 04, 2024
Tax Court Turns Down Whistleblower's Push To Boost Award
Though a tax whistleblower contended he should be entitled to a reward based on the entire amount of deficiencies discovered in a large investigation, the IRS was right to calculate his reward based only on the specific taxpayer he identified, the U.S. Tax Court said Tuesday.
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June 04, 2024
House Bill Would Cut $2B In IRS Funding, Restrict Direct File
The chairman of the House Appropriations subcommittee that handles Internal Revenue Service funding introduced legislation Tuesday to cut that funding for fiscal 2025 by over $2 billion and prohibit money from going to the agency's free online tax-filing program without congressional approval.
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June 04, 2024
11th Circ. Affirms Nix Of IRS Easement Disclosure Guidance
The Eleventh Circuit affirmed Tuesday that an Internal Revenue Service notice imposing reporting requirements on potentially abusive conservation easements was invalid because the agency failed to solicit the public feedback required by administrative law.
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June 04, 2024
IRS Announces 6 Tax Court Sessions Added To Calendar
The Internal Revenue Service announced six U.S. Tax Court sessions in October and named calendar administrators for the sessions in a notice released Tuesday.
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June 04, 2024
IRS Didn't Have To Tell Man About Summonses, 5th Circ. Told
The Internal Revenue Service wasn't required to tell a Texas man with unpaid tax liabilities that it had demanded his financial information from third parties, the agency told the Fifth Circuit, urging it to affirm a lower-court decision tossing the man's suit challenging the summonses.
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June 03, 2024
FTX, IRS Propose Settling $8B Tax Fight For Just $885M
FTX and the Internal Revenue Service have reached a proposed settlement worth roughly $885 million that would resolve the agency's contention that the bankrupt cryptocurrency exchange operator owes $8 billion in taxes, according to a motion filed Monday in Delaware federal bankruptcy court.
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June 03, 2024
Danish Tax Agency Says $2.1B Tax Fraud Suits Not Filed Late
Denmark's tax administrator urged a New York federal court to reject bids to toss its suits against U.S. pension plans and individuals it accuses of participating in a $2.1 billion fraud scheme, saying the suits were not filed too late.
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June 03, 2024
Treasury Aims To Salvage Corp. Transparency Act At 11th Circ.
The Corporate Transparency Act is a valid exercise of congressional authority to curb money laundering under the commerce clause and the necessary and proper clause in the Constitution, the U.S. Treasury Department told the Eleventh Circuit on Monday in a bid to restore the law's reporting requirements.
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June 03, 2024
Suzanne Somers' Estate Owes $2.7M, Tax Court Says
Television producer Alan Hamel and the estate of his wife, actor Suzanne Somers, owe nearly $2.7 million in taxes and penalties going back to 1996 related to losses in a partnership, the U.S. Tax Court ruled Monday.
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June 03, 2024
IRS Correctly Denied Man Collection Alternative, Court Says
The Internal Revenue Service did not abuse its discretion when rejecting a Florida man's collection alternative request, the U.S. Tax Court said Monday.
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June 03, 2024
Couple Can't Justify $3.7M Loss Deduction, Tax Court Says
A New York couple failed to adequately prove that they should have been able to claim $3.7 million in net operating losses on their personal income taxes that were generated by settlement payments made by a company they owned, the U.S. Tax Court said Monday.
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June 03, 2024
Tax Convictions Withstand Poor Counsel Claim, 4th Circ. Says
A North Carolina man's claim of ineffective counsel is not sufficient reason to vacate his convictions for filing false tax returns and obstructing an official proceeding in a case involving $2.1 million in unreported income sent from Bermuda entities, the Fourth Circuit ruled.
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June 03, 2024
Google Must Face Online Tax Filer's Privacy Suit
An Illinois woman who prepared her taxes online through H&R Block and then sued Google, claiming the search engine's tracking tool effectively eavesdropped on her confidential tax information, can move forward with her proposed class action, a California federal judge ruled Monday.
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June 03, 2024
Texas Oil Co. Says IRS Hasn't Paid $36M Promised Refund
The Internal Revenue Service has promised to pay a Texas oil company more than $36 million in tax refunds and credits for the 2009 tax year but has failed to do so, the company told a federal court.
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June 03, 2024
Vanguard Investors Want Class Cert. In Tax Liability Fight
Investors accusing Vanguard and its top brass of violating its fiduciary duties by triggering a sell-off of assets in target retirement funds in an attempt to lower fees, leaving smaller investors with massive tax bills, asked a Pennsylvania federal court to certify them as a class.
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June 03, 2024
Taxes Take Center Stage In Pot Industry Amid Fed. Policy Shift
The federal government's move to loosen restrictions on cannabis is expected to trigger a wave of mergers and acquisitions structured as asset deals in the industry, especially among struggling retail operations willing to restructure in order to raise profits and lower their tax liabilities.
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June 03, 2024
Weekly Internal Revenue Bulletin
The Internal Revenue Service issued its weekly bulletin, which included an updated list of procedures for taxpayer-initiated requests for changes in methods of accounting.
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June 01, 2024
Blockbuster Summer: 10 Big Issues Justices Still Must Decide
As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.
Expert Analysis
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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How IRA Unlocks Green Energy Investments For Tribes
An Inflation Reduction Act provision going into effect May 10 represents a critical juncture for Native American tribes, offering promising economic opportunity in green energy investment, but requiring a proactive and informed approach when taking advantage of newly available tax incentives, say attorneys at Lewis Brisbois.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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What To Know About IRS' New Jet Use Audit Campaign
The Internal Revenue Service recently announced plans to open several dozen audits scrutinizing executive use of company jets, so companies should be prepared to show the business reasons for travel, and how items like imputed income and deduction disallowance were calculated, say attorneys at Morgan Lewis.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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What To Know About Employee Retention Credit Disclosures
Employers that filed potentially erroneous employee retention credit claims should take certain steps to determine whether the IRS’ voluntary disclosure program is a good fit and, if so, prepare a strong application before the window closes on March 22, say attorneys at Dentons.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.