Consequently, on November 3, 2021, the taxpayer requested an extension of the time to the IRS under Treas. Reg. § 301.9100-3.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

On Monday, Texas Lieutenant Governor Dan Patrick and Texas House Speaker Dale Phelan released a joint statement announcing their agreement to propose legislation that will deliver...

Short Summary: Celia Mazzei, the taxpayer, appealed a Tax Court decision to the U.S. Court of Appeals for the Ninth Circuit. Originally, the Tax Court found Mazzei liable for excise taxes...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Under the Internal Revenue Code, the IRS can satisfy a tax deficiency by imposing a lien on any "property" or "rights to property" belonging to the taxpayer.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

On March 11, 2022, the Joint Committee on Taxation published its 49-page report (the "Report") relating to the federal tax treatment of charitable contributions.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

The doctrine of res judicata, or claim preclusion, bars a second action by parties and those in privity with them on matters actually litigated in a previous suit, as well as claims that could...

What is an "alter ego?" The phrase is Latin, translating to "second I," "another I," or "other self." In the federal tax context, the alter ego doctrine comes into play where the IRS...

Freeman Law's "The Tax Court in Brief" covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.

Last week, I posted a brief summary of sales tax issues related to software and computer programs. However, as the characterization and taxability of "data processing" is such a complex and hotly...