Federal

  • June 06, 2024

    9th Circ. Denies Trust Refund Of Money Forfeited To IRS

    A trust lost its ownership claims to property when an Idaho federal court determined the property had been transferred to the trust fraudulently, the Ninth Circuit said Thursday, affirming a decision to deny a $225,000 tax refund.

  • June 06, 2024

    Estate Entitled To Deduct Payouts To Stepkids, 11th Circ. Told

    The U.S. Tax Court wrongly denied deductions to a former attorney's $81 million estate for million-dollar payouts it made to his stepchildren after they sued, the estate told the Eleventh Circuit, saying the payments satisfied legitimate claims against the estate and were therefore deductible.

  • June 06, 2024

    Tax Court Upholds Rejection Of Man's Biz Deductions

    A Floridian failed to adequately back up certain business loss deduction claims made on his tax return, the U.S. Tax Court said Thursday, backing the IRS' rejection of the claims and imposition of an accuracy-related penalty.

  • June 06, 2024

    'Brothel' Manager Violated Bail After $5.7M Sting, Feds Say

    A manager and bookkeeper facing federal charges connected to a COVID-19 grant and tax fraud scheme at a Connecticut strip club violated his bail conditions by showing up at the facility and "hanging out" with a potential witness, federal probation authorities have alleged.

  • June 06, 2024

    9th Circ. Won't Revive Org's Push To Restore Nonprofit Status

    The U.S. Tax Court's dismissal of an attempt to reinstate nonprofit status for a California organization that said its officers fell victim to a Ponzi scheme did not breach the group's constitutional rights, the Ninth Circuit said.

  • June 06, 2024

    Ex-IRS Worker Indicted In $2M Exxon Credit Theft Scheme

    A former Internal Revenue Service employee used his account management job at the agency to steal more than $2 million worth of tax credits from Exxon Mobil and pocket the money, according to a Utah federal grand jury indictment.

  • June 06, 2024

    Fox Rothschild Brings On Tax Pro From Atlanta Boutique

    Fox Rothschild LLP has added an attorney in Atlanta from tax law boutique Wiggam Law to strengthen the firm's taxation and wealth planning department.

  • June 06, 2024

    IRS Needs Strategy For 2.6M Tax Doc Backlog, TIGTA Says

    Not only does the Internal Revenue Service have a document backlog exceeding 2.6 million source documents that need to be associated with a specific form, but it also has been making significant mistakes in reporting closures, the Treasury Inspector General for Tax Administration said in a report released Thursday.

  • June 05, 2024

    CohnReznick Scores Quick Exit In Tax Scheme Suit

    A New York federal judge agreed to toss a housing partnership's suit accusing accounting firm CohnReznick LLP of professional negligence and fraud, finding that the district court doesn't have jurisdiction over the dispute.

  • June 05, 2024

    IRS Must Better Log AI Use In Tax Gap Estimates, GAO Says

    The Internal Revenue Service needs to complete documentation on its use of artificial intelligence models as part of a plan to improve its tax gap estimates, the Government Accountability Office said Wednesday.

  • June 05, 2024

    Californian Failed To Report Missing Income, Tax Court Says

    A California woman's contention that she should not be accountable for a deficiency in her 2021 tax filing due to what she said was an error by her accountant doesn't stand up under scrutiny, the U.S. Tax Court said Wednesday.

  • June 05, 2024

    Some Payments After Train Derailed Aren't Taxable, IRS Says

    Certain payments from Norfolk Southern Corp. to victims of its freight train derailment and toxic chemical spill in East Palestine, Ohio, are considered disaster relief payments and are therefore not taxable, the Internal Revenue Service said Wednesday.

  • June 05, 2024

    House Panel Tees Up $2B In IRS Cuts For Full Committee Vote

    A House Appropriations subcommittee approved legislation Wednesday that would reduce Internal Revenue Service 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Featured Stories

  • Taxes Take Center Stage In Pot Industry Amid Fed. Policy Shift

    Stephen K. Cooper

    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.

  • IRS Guidance Narrows Spinoffs Available For Preapproval

    Natalie Olivo

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • 5 Tax Bills To Watch This Summer

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    House and Senate lawmakers return to Washington, D.C., on Monday, where several tax-related bills await them in both chambers, including a stalled package that would restore business tax breaks and expand the child tax credit. Here, Law360 takes a look at five bills that could move through Congress this summer.

Expert Analysis

  • Fishing Makes Me A Better Lawyer

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    Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge​​​​​​​ at Robinson Bradshaw.

  • A Healthier Legal Industry Starts With Emotional Intelligence

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    The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.

  • To Make Your Legal Writing Clear, Emulate A Master Chef

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    To deliver clear and effective written advocacy, lawyers should follow the model of a fine dining chef — seasoning a foundation of pure facts with punchy descriptors, spicing it up with analogies, refining the recipe and trimming the fat — thus catering to a sophisticated audience of decision-makers, says Reuben Guttman at Guttman Buschner.

  • Circuit Judge Writes An Opinion, AI Helps: What Now?

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    Last week's Eleventh Circuit opinion in Snell v. United Specialty Insurance, notable for a concurrence outlining the use of artificial intelligence to evaluate a term's common meaning, is hopefully the first step toward developing a coherent basis for the judiciary's generative AI use, says David Zaslowsky at Baker McKenzie.

  • BF Borgers Clients Should Review Compliance, Liability

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    After the U.S. Securities and Exchange Commission's recently announced enforcement proceedings against audit firm BF Borgers for fabricating audit documentation for hundreds of public companies, those companies will need to follow special procedures for disclosure and reporting — and may need to prepare for litigation from the plaintiffs bar, say attorneys at Debevoise.

  • Trauma-Informed Legal Approaches For Pro Bono Attorneys

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    As National Trauma Awareness Month ends, pro bono attorneys should nevertheless continue to acknowledge the mental and physical effects of trauma, allowing them to better represent clients, and protect themselves from compassion fatigue and burnout, say Katherine Cronin at Stinson and Katharine Manning at Blackbird.

  • What Updated PLR Procedure May Mean For Stock Spin-Offs

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    A recently published Internal Revenue Service revenue procedure departs from commonly understood interpretations of the spinoff rules by imposing more stringent standards on companies seeking private letter rulings regarding tax-free stock spinoff and split-off transactions, and may presage regulatory changes that would have the force of law, say attorneys at Skadden.

  • Proposed Cannabis Reschedule Sidesteps State Law Effects

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    The U.S. Department of Justice's recent proposal to move cannabis to Schedule III of the Controlled Substances Act provides certain benefits, but its failure to address how the rescheduling would interact with existing state cannabis laws disappointed industry participants hoping for clarity on this crucial question, says Ian Stewart at Wilson Elser.

  • How Attys Can Avoid Pitfalls When Withdrawing From A Case

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    The Trump campaign's recent scuffle over its bid to replace its counsel in a pregnancy retaliation suit offers a chance to remind attorneys that many troubles inherent in withdrawing from a case can be mitigated or entirely avoided by communicating with clients openly and frequently, says Christopher Konneker at Orsinger Nelson.

  • Using A Children's Book Approach In Firm Marketing Content

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    From “The Giving Tree” to “Where the Wild Things Are,” most children’s books are easy to remember because they use simple words and numbers to tell stories with a human impact — a formula law firms should emulate in their marketing content to stay front of mind for potential clients, says Seema Desai Maglio at The Found Word.

  • New Crypto Reporting Will Require Rigorous Recordkeeping

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    The release of a form for reporting digital asset transactions is a pivotal moment in the Internal Revenue Service's efforts to track cryptocurrency activities that increases oversight by requiring brokers to report investor sales and exchanges, say Shaina Kamen and Max Angel at Holland & Knight.

  • Geothermal Energy Has Growing Potential In The US

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    Bipartisan support for the geothermal industry shows that geothermal energy can be an elegant solution toward global decarbonization efforts because of its small footprint, low supply chain risk, and potential to draw on the skills of existing highly specialized oil and gas workers and renewable specialists, say attorneys at Weil.

  • Exploring An Alternative Model Of Litigation Finance

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    A new model of litigation finance, most aptly described as insurance-backed litigation funding, differs from traditional funding in two key ways, and the process of securing it involves three primary steps, say Bob Koneck, Christopher Le Neve Foster and Richard Butters at Atlantic Global Risk LLC.