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  • Article

    Texas Tax Roundup—May 2022

    Howdy folks, and welcome back to another captivating installment of Texas Tax Roundup, where we gab about all things Texas taxes. Nothing court-side this month, just a bunch at the administrative level.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Tax Court In Brief | Serna v. Commissioner | Collection Due Process, Offer In Compromise, And Hardship

    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.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Texas Sales And Use Tax Rules For Construction-Related Services

    The Texas sales and use tax rules surrounding contractors and other construction-related work are incredibly complex. Additionally, the rules are structured to have broad application...
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Taxation Of Crypto Mining

    Amid the crypto boom, mining has become an extremely lucrative venture for many and critical to maintaining decentralized cryptocurrency networks.
    United StatesTechnology
    Freeman Law
    Freeman Law
  • Article

    Tax Court In Brief | Lipka V. Comm'r | Collection Alternatives, Economic Hardship, And Abuse Of Discretion

    The Lipkas filed their tax return for year 2017 and reported income tax liability of $466,076. But, they did not pay that liability.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Changes To Corporate Capital In Equity Financing Transactions

    Experienced entrepreneurs and investors alike understand that equity dilution is a fundamental aspect of investing in corporations.
    United StatesCorporate/Commercial Law
    Freeman Law
    Freeman Law
  • Article

    Fraudulent Transfers

    Over the last 45 days, I have litigated four separate fraudulent transfer adversary proceedings in Bankruptcy Court. Through that experience, I have not only reinforced certain principles, but also clarified others and learned a few things along the way.
    United StatesCriminal Law
    Freeman Law
    Freeman Law
  • Article

    Effectively Connected Income

    Unlike FDAP income, the United States taxes effectively connected income ("ECI") on a net basis.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Tax Court In Brief | Scholtz v. Commissioner | Itemized Deductions, Charitable Contributions And Unreimbursed Employee Expenses

    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.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Violations Of The Bankruptcy Discharge Injunction

    The recent case of In re Micah Cade McKinney, Case No. 21-50046-rlj-11 (Bankr. N.D. Tex., April 28, 2022)
    United StatesInsolvency/Bankruptcy/Re-Structuring
    Freeman Law
    Freeman Law
  • Article

    Lawyers And Leadership – Trust Is More Important Now Than Ever

    In November 2003, I was sworn in as a lawyer licensed by the State of Texas.
    United StatesLaw Department Performance
    Freeman Law
    Freeman Law
  • Article

    Yeah, Science! IRS Issues Guidance Section 501(c)(3) Scientific Organizations

    In the Netflix series, Breaking Bad, character Jesse Pinkman exclaimed, "Yeah, Science!!" as his meth-lab mentor, Walter White, displayed how chemistry can be used to hone their joint venture.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Holding Digital Assets Through Custodial Wallets

    The recent headlines regarding cryptocurrency exchange FTX's collapse, and subsequent bankruptcy filing have put renewed focus on whether customers of a cryptocurrency exchange should hold digital...
    United StatesTechnology
    Freeman Law
    Freeman Law
  • Article

    Tax Court In Brief | Furrer V. Comm'r | Charitable Remainder Trusts; Non-Cash Charitable Contribution Substantiation; Taxability Of CRAT Distributions

    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.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Court Declares IRS Micro-Captive Notice 2016-66 Unlawful: What Taxpayers Should Do Now

    On May 17, 2021, the United States Supreme Court handed the IRS a significant loss when it concluded that CIC Services, LLC ("CIC") could continue its lawsuit against the IRS for violations of...
    United StatesLitigation, Mediation & Arbitration
    Freeman Law
    Freeman Law
  • Article

    IRS Lacks Statutory Authority To Assess Certain Form 5471 Penalties

    The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated...
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Lien Withdrawal

    A federal tax lien, sometimes called a "statutory lien," is the government's legal claim against a taxpayer's property when the taxpayer neglects or fails to pay a tax debt.
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Taxpayers' Failure To File Form 3520 And Form 3520-A Results In Extended Statute Of Limitations Period: The Cautionary Tale Of Fairbank

    In the federal income tax world, there are effectively two functions within the Internal Revenue Service ("IRS"). First, the IRS examines tax years and tax returns to determine whether...
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Texas Legislative Update | Qualified Projects

    The Texas Legislature enacted four bills that 1) expand the list of cities that can build qualified projects (i.e., hotel and convention center projects subject to certain specifications) under Texas...
    United StatesTax
    Freeman Law
    Freeman Law
  • Article

    Ponzi Schemes And The Theft Loss Deduction

    Every few months or so seem to bring new revelations of a Ponzi scheme gone bust.
    United StatesCriminal Law
    Freeman Law
    Freeman Law

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