Recent Articles
Tax Court Says IRS Can’t Charge Penalties for Foreign Corporation Reporting
Taxpayer Avoids IRS Penalty in Foreign Business Reporting Case The Tax Court recently ruled that the IRS does not have the authority to impose penalties on taxpayers who fail to report ownership of foreign corporations under Code Sec. 6038(b). This...
Estate Not Liable for Gift Tax on Shares From Terminated Trusts
Tax Court rules no gift tax on shares received or sold after trust termination. The Tax Court ruled that an estate was not liable for gift tax on shares received from a terminated marital trust. The case involved a taxpayer,...
90-Day Deadline for Employment Tax Petition: Not the Final Word
Missed the IRS 90-day petition deadline? The Tax Court says you may still have options! The Tax Court has ruled that the 90-day deadline for filing a petition to challenge an IRS employment tax determination is not a jurisdictional requirement....
Children’s Gift to Father Triggered by Residuary Trust Commutation
Tax Court Determines Gift Tax Implications for Trust Agreement When a residuary trust was commuted, the Tax Court ruled that the children of the trust’s income beneficiary made a gift to their father. This decision sheds light on how tax...
Tax Court Denies Innocent Spouse Relief for Erroneous Refund of Interest
Understanding the Limits of Innocent Spouse Relief for Tax Liabilities: Insights from a Taxpayer’s Case A taxpayer wife was denied equitable innocent spouse relief by the Tax Court in a reviewed opinion issued on July 17, 2024. The court determined...
Navigating the Unused Digital Asset Basis Safe Harbor
Advice for Practitioners: Simplifying the IRS’s Latest Guidance on Digital Asset Reporting The IRS has introduced significant updates on digital asset reporting, giving taxpayers an opportunity to manage unused basis before new rules take effect in 2025. These changes, outlined...