Podcasts about Tax court

Another Circuit looks into the equitable tolling issue for Tax Court deficiency petitions, an US Air Force civilian contractor issued orders to move cannot claim moving expenses and more.

Taxpayer fails to justify equitable relief for late filing of employment tax related Tax Court petition, Tax Court found horse operation was subject to the hobby loss rules and more.

https://vimeo.com/1070813367?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/3/30/2025-03-31-end-of-paper-tax-payments-and-refund-checks-coming This week we look at: Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021 Interim Final Rule Limiting BOI Filing Requirements Released by Treasury Department Substantiating Depreciation for Converted Property: A Look at Smith v. Commissioner Executive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related Ones Jones et al. v. Commissioner: A Deep Dive into the Tax Court's Scrutiny of a Microcaptive Insurance Arrangement Navigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United States Ninth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAs

This week we look at:Congress Passes Resolution to Nullify Final Regulations on DeFi Information Reporting in TD 10021Interim Final Rule Limiting BOI Filing Requirements Released by Treasury DepartmentSubstantiating Depreciation for Converted Property: A Look at Smith v. CommissionerExecutive Order Will Generally Bar the Use of Paper Checks to Make Payments to or Receive Refunds from Treasury, Including Tax Related OnesJones et al. v. Commissioner: A Deep Dive into the Tax Court's Scrutiny of a Microcaptive Insurance ArrangementNavigating Jurisdictional Hurdles in Tax Refund Claims: A Look at Hamilton v. United StatesNinth Circuit Affirms Willful Failure to Pay Trust Fund Taxes: A Case Study for CPAsAn audio only version of this week's broadcast can be streamed or downloaded below: Articles on this week's update can be downloaded below:2025-03-31 Current Federal Tax Developments

Chris's Summary:This week's EDU show is a throwback to an old favorite—things that make you go “hmm.” Jim brought back a list of oddities from the latest Ed Slott training, covering everything from RMD rules the IRS only recently addressed to real-world court cases involving bankruptcy, lottery tickets, and IRA self-dealing gone wrong. Turns out, […] The post Things That Make You Go Hmm – RMD Rules, IRA Mistakes, and Tax Court Surprises: EDU #2512 appeared first on The Retirement and IRA Show.

This Day in Legal History: Nuclear Non-Proliferation TreatyOn March 5, 1970, the Nuclear Non-Proliferation Treaty (NPT) officially took effect, marking a major milestone in global efforts to prevent the spread of nuclear weapons. The treaty, first opened for signatures in 1968, was ratified by 43 nations and established a framework based on three core principles: non-proliferation, disarmament, and the peaceful use of nuclear energy. Under its terms, nuclear-armed states agreed not to transfer nuclear weapons or technology to non-nuclear states, while non-nuclear countries pledged not to pursue nuclear weapons. In return, signatories were guaranteed access to nuclear energy for peaceful purposes, such as power generation and medical research. The treaty also called for eventual nuclear disarmament, though progress on this front has been slow and uneven. The NPT has since become one of the most widely adhered-to arms control agreements, with 191 countries now party to it. However, key states like India, Pakistan, and Israel never joined, while North Korea withdrew in 2003. The treaty's effectiveness has been challenged by nuclear programs in states like Iran and North Korea, as well as concerns over compliance by nuclear-armed signatories. Despite these challenges, the NPT is reviewed every five years at Review Conferences, where nations assess progress and negotiate future commitments. The treaty remains central to international non-proliferation efforts, balancing national security interests with the goal of reducing nuclear threats worldwide.In his primetime address to Congress, President Donald Trump defended his aggressive tariff policies, claiming they would generate significant revenue and restore economic balance. He downplayed concerns over rising consumer prices, characterizing them as a temporary inconvenience. While Trump briefly addressed inflation, blaming high costs on his predecessor, he provided few concrete solutions. Instead, he focused on politically charged topics like immigration and cultural issues, declaring an end to "wokeness." His speech coincided with growing economic concerns, including stagnating factory activity and declining consumer confidence, while markets reacted negatively to escalating trade tensions. New tariffs on Canada, Mexico, and China sparked fears of inflation and economic slowdown, though his administration suggested potential relief for North American allies. Trump also called for the repeal of the Chips Act, arguing tariffs were more effective in boosting domestic industry. He promoted energy independence but proposed long-term projects unlikely to have an immediate impact. Meanwhile, his executive actions have rapidly reshaped government policies, sparking bipartisan concerns. The speech underscored Trump's efforts to push his economic agenda while navigating political and economic challenges.Trump Hails Tariffs as US Economy Barrels Into Trade WarsThe U.S. Tax Court ruled that a $3.1 million grant given to a Cantor Fitzgerald subsidiary after the Sept. 11 attacks is taxable income. The grant, provided in 2007 through New York City's World Trade Center Job Creation and Retention Program, was meant to help businesses recover, but the court determined it did not qualify as a tax-exempt gift or disaster aid. Despite this, the court waived $211,000 in penalties, acknowledging the complexity of tax laws at the time. Cantor Fitzgerald, which lost 658 employees in the World Trade Center attacks, had argued the funds should not be considered taxable, citing past Supreme Court rulings. However, Judge Kathleen M. Kerrigan found that the payments were not an act of disinterested generosity but an effort to stimulate economic recovery. The IRS had initially determined in 2007 that the company owed about $1.1 million in taxes for not reporting the grant on its tax returns. While Cantor Fitzgerald contested the classification, the court upheld the IRS's position, reinforcing that government aid programs do not automatically qualify for tax exemption.Cantor Fitzgerald's Sept. 11 Relief Grant Deemed Taxable IncomeFederal judges are facing an increase in threats as Elon Musk and Trump allies intensify their attacks on the judiciary over rulings that hinder White House policies. The U.S. Marshals Service has warned judges about heightened security risks, especially as Musk has repeatedly criticized judges on his social media platform, calling them “corrupt” and “evil.” Some judges have received anonymous deliveries, like pizzas, in what authorities see as intimidation tactics. Musk's posts, along with calls from Republican lawmakers to impeach certain judges, have coincided with a rise in violent threats, particularly against judges who have blocked parts of the administration's plans to cut government jobs and aid programs. One judge, Amir Ali, received death threats after ruling against a Trump executive order, with online users calling for his execution. The American Bar Association and the Federal Judges Association have condemned these attacks, warning that continued intimidation could undermine judicial independence. Since 2020, threats against federal judges have more than doubled, and legal experts caution that targeting judges for their rulings could destabilize the rule of law.Exclusive: Judges face rise in threats as Musk blasts them over rulings | ReutersTwo Trump EPA nominees are facing Senate scrutiny over the agency's possible plan to roll back the 2009 “endangerment finding,” which forms the legal basis for regulating greenhouse gas emissions under the Clean Air Act. The nominees, Aaron Szabo and David Fotouhi, would oversee efforts to reverse this finding, which has supported climate regulations on power plants and vehicle emissions. EPA Administrator Lee Zeldin has recommended reconsidering the finding to the White House, though details remain undisclosed. While the Supreme Court's 2007 ruling in Massachusetts v. EPA confirmed greenhouse gases as air pollutants, the 2022 Inflation Reduction Act further solidified the EPA's authority. However, the EPA under Trump previously avoided overturning the rule due to industry resistance. Some industry groups, like the Edison Electric Institute, have expressed reliance on EPA authority for emissions regulation, while automakers have yet to take a position. Zeldin acknowledged the EPA's authority to regulate greenhouse gases but suggested it is not obligated to do so, fueling debate over the agency's future climate policies.Top EPA nominees face Senate scrutiny over plan to undo key climate finding | Reuters This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit www.minimumcomp.com/subscribe

Intro Summary] In this follow-up episode of Absolute Trust Talk, host Kirsten Howe welcomes back tax law expert Tony Kim to continue their deep dive into IRS audits and appeals. With 26 years of experience working for the IRS, Tony provides invaluable insights into what happens after an audit determination is made. He explains the role of a protest letter, how appeals officers function as mediators, and why IRS litigation can be risky for taxpayers. Throughout the episode, Tony emphasizes the importance of organization, professionalism, and strategic decision-making when dealing with the IRS. He also shares real-world examples of how cases are resolved at different stages of the appeals process. If you're facing an IRS audit or just want to understand your rights, this episode is packed with essential knowledge.   Time-stamped Show Notes: 0:00 Introduction 1:33 The protest letter: Here's what you need to know about how it challenges IRS decisions. 4:20 Appeals officers vs. revenue agents—who decides your case? 6:16 The power of appeals—why 90% of cases never reach court. Here's why. 8:50 Tax Court vs. District Court: Listen in as Kirsten and Tony discuss the key differences and taxpayer options. 10:44 The IRS attorney's role—can they make things better or worse? 14:31 Next, Tony is sharing important strategies for working effectively with the IRS—what really works? 19:38 How do you determine what to look for when selecting the right tax attorney? Tune in for key considerations. 23:37 Final advice—why staying engaged in your case is crucial!

Attorney George Smith is a highly respected and well-known attorney throughout the State of Alabama.  As most attorneys in the state know George, I have known him by reputation, and this is really the first time for me to speak in depth with him. George is a graduate of the University of Alabama School of Law and he also received an LLM in tax law from the New York University School of Law. Following that, he clerked in Washington DC for a judge on the U.S. Tax Court for two years before returning back to Huntsville to start his law practice.  George has practiced with large Alabama law firms throughout his career.  He has been at Bradley since 2012.  As you'll hear, even with his impressive background, George is easy to talk to and I can well imagine that his clients appreciate the skill and practicality he brings as he represents them.  Since George has practiced in “big law” for his entire legal career, we also discussed a number of his friends and colleagues that are also very prominent lawyers in Alabama to include Pat Graves, Frank Caprio, Bartley Loftin, David Holt, Kevin Gray, Chris Hinson and Joe Ritch. I enjoyed getting to know George on this episode of the podcast and I think you will like his humble and up-tempo spirit!  

This lecture begins by outlining the historical and constitutional roots of the federal income tax. Early in American history, the federal government used excise taxes and tariffs to raise revenue, and only in special circumstances, such as the Civil War, did it introduce temporary income taxes. The Sixteenth Amendment in 1913 dramatically shifted the legal landscape, giving Congress the authority to impose an income tax without the need for apportionment among the states. This development paved the way for modern federal income taxation, removing most constitutional barriers that had previously hindered direct taxation of individual incomes.Next, the lecture covers how the federal tax system is organized. The Internal Revenue Service (IRS) enforces tax laws and issues guidance, while the Treasury Department oversees both the IRS and broader financial policies. Various authorities define tax law: the Internal Revenue Code (IRC) enacted by Congress; Treasury Regulations that interpret and clarify the Code; official Revenue Rulings and procedures from the IRS; and judicial decisions at multiple levels, including the U.S. Tax Court, district courts, courts of appeal, and potentially the Supreme Court. Together, these sources form a complex legal framework that practitioners must navigate.Tax policy goals also factor into the system's structure. While the primary purpose of taxation is to fund government operations, Congress uses the tax code to shape economic and social behavior, encouraging homeownership via mortgage interest deductions or fostering charitable giving through donation write-offs. This means that the Code is more than just a revenue-raising tool; it's also a mechanism for incentivizing and discouraging certain activities.A significant portion of the lecture is devoted to gross income, a concept anchored by IRC Section 61. This broad definition—“all income from whatever source derived”—captures wages, business profits, interest, dividends, rents, and many other forms of economic gain. Even illegal proceeds and certain prizes count as gross income, reflecting the principle that if a taxpayer obtains a clear economic benefit, it is presumed taxable. Nevertheless, there are notable exclusions: gifts, inheritances, certain fringe benefits, and life insurance proceeds are among the items that Congress or the courts have decided should not be included in gross income. Sometimes, these exclusions further a policy objective, such as not penalizing individuals receiving gifts or not taxing life insurance benefits that mitigate financial burdens upon death.The lecture then introduces the importance of filing status: single, married filing jointly, married filing separately, head of household, and qualifying widow(er). Each status affects how taxpayers fall into brackets in the progressive tax system, where higher marginal rates apply to additional increments of income. The system aims to tax those with greater resources more heavily, though fairness and efficiency debates remain. Thus, individuals with the same gross income may pay different effective tax rates, influenced by both filing status and the presence of deductions or credits.Finally, the lecture underscores the policy rationales embedded in the tax code. Deductions for retirement contributions or energy-efficient home improvements reveal the government's intent to channel societal behaviors. Because these incentives directly affect how people earn, save, and invest, attorneys and other professionals must understand both the letter of the law and the broader purpose it serves.Overall, Lecture 1 underscores that modern federal income taxation rests on a constitutional foundation, shaped by the Sixteenth Amendment, enforced by a multi-tier system of statutes, regulations, and court rulings, and guided by deliberate policy goals. The core concept of “gross income”—and the many exceptions that reduce it—forms the building block for tax liability calculation

This week we look at: IRS issues letter ruling on IRA left to trust A taxpayer mistakenly believes the IRS had conceded that his income was not subject to self-employment tax, but it hadn't The Tax Court denies a taxpayer's deductions and claimed partnership losses due to incredibly disorganized and inadequate records Taxpayer runs afoul of the “pay first, litigate later” rule when attempting to sue the IRS for a refund in US District Court in response to an assessment A taxpayer's unprocessed claim for an ERTC refund doesn't justify CDP relief The BOI - new Administration continues litigation and proposes a new due date, potential filing relief

https://vimeo.com/1052761467?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/2/2/2025-02-03-a-week-of-tax-court-rulings This week we look at: Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return IRS Finds Most Expenses Related to Taxpayers' In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213 Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion Tax Court Finds No Issue With the Appeals Office Structure and Staffing Failure to Provide Proof of Filing of Returns Fatal to Taxpayer's Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors

Tax Court reduces donation amount to less than 1/3 of original amount claimed, taxpayer's decision to play hardball in a collection issue backfires. and more.

This week we look at: Tax Court Finds Property Donated to Charity Had a Value Less than One-Third of What Taxpayers Claimed on Return IRS Finds Most Expenses Related to Taxpayers' In Vitro Fertilization and Surrogacy Will Not Be Deductible Medical Expenses Under IRC §213 Taxpayer Denied Innocent Spouse Relief in Tax Court Bench Opinion Tax Court Finds No Issue With the Appeals Office Structure and Staffing Failure to Provide Proof of Filing of Returns Fatal to Taxpayer's Attempt at Obtaining Relief in CDP Hearing Despite IRS Procedural Errors

Stephen Grootes speaks to Jean-Roux van Huyssteen, Director & Tax Attorney at TRM Tax AttorneysTax about a landmark victory against SARS in the tax court, which sets a significant precedent for taxpayers, businesses, and the broader industrySee omnystudio.com/listener for privacy information.

https://vimeo.com/1048354337?share=copy#t=0 https://www.currentfederaltaxdevelopments.com/podcasts/2025/1/19/2025-01-20-secure-20-act-proposed-guidance This week we look at: IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property Proposed regulations on catch-up contributions added by the SECURE 2.0 Act Proposed regulations on the automatic enrollment provisions of IRC §414A US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019

IRS releases two sets of proposed regulations under the SECURE 2.0 Act, IRS agrees to hear case on Tax Court jurisdiction in CDP cases and more.

This week we look at: IRS updates residential energy credit Fact Sheet, adds details about the PIN requirements that take effect for 2025 property Proposed regulations on catch-up contributions added by the SECURE 2.0 Act Proposed regulations on the automatic enrollment provisions of IRC §414A US Supreme Court agrees to review a Third Circuit ruling on Tax Court jurisdiction in a Collection Due Process case IRS issues final regulations on resolution of tax controversies by the IRS Independent Office of Appeals Under TFA of 2019

This week we look at: IRS gives relief for specific identification of digital asset basis for certain taxpayers for 2025 only Department of Justice asks the U.S. Supreme Court to Stay the Latest Corporate Transparency Act Injunction IRS no longer to dispute requirement to comply with APA to add listed transactions after the enactment AJCA in 2024 Tax Court rules that merely being in a registered historic area does not make a building a certified historic structure Tax Court finds taxpayer owes tax on over $5.3 million diverted from two retirement plans

BOI updates continue throughout the week, Ninth Circuit rules on all events test issue and Tax Court again imposes functional test on state law limited partners

Jeannette is joined by Dr Kameel Khan,a lawyer, judge, and founder of Project Remake, about his inspiring journey from Trinidad to the UK and his commitment to social justice. Kameel shares his early influences, including the civil unrest in Trinidad and the impact of his parents' belief in education. He also discusses his experiences defending death row inmates and the complexities of the justice system, highlighting the importance of understanding the human stories behind offenders. KEY TAKEAWAYS The journey into law and social justice was significantly influenced by early education and the support of family, highlighting the role of encouragement and vision in shaping one's future. Understanding the personal stories and backgrounds of offenders is crucial. They are not just statistics; they are individuals with families and potential who deserve a second chance. Project Remake, which started at Stanford University, focuses on entrepreneurship training for formerly incarcerated individuals, achieving a remarkable 6% reoffending rate compared to the national average of 54%. The financial burden of incarceration is significant, with costs reaching £50,000 per year per inmate. Investing in rehabilitation and employment opportunities for ex-offenders can lead to better societal outcomes and reduced costs. BEST MOMENTS "We have had 120 graduates, and we have had a 6% reoffending rate... The national average is near 54% in the first year and 70% in the second year." "We want to live in a society that doesn't write people off, that gives people a second chance." "How do we break that sort of aspect of judgment around this whole topic? Because I think that's a really big blocker as well, the perception." "It's very interesting... finding your voice is a huge thing... realising you could only be you, everyone else is taken." This is the perfect time to get focused on what YOU want to really achieve in your business, career, and life. It’s never too late to be BRAVE and BOLD and unlock your inner BRILLIANT. Visit our new website https://brave-bold-brilliant.com/ - there you'll find a library of FREE resources and downloadable guides and e-books to help you along your journey. If you’d like to jump on a free mentoring session just DM Jeannette at info@brave-bold-brilliant.com. VALUABLE RESOURCES Brave Bold Brilliant - https://brave-bold-brilliant.com/ Brave, Bold, Brilliant podcast series - https://podcasts.apple.com/gb/podcast/brave-bold-brilliant-podcast/id1524278970 ABOUT THE GUEST Kameel Khan is a lawyer, judge and former law professor. Before practicing he taught law at University College, University of London, Reading University and the University of the West Indies. He was a Visiting Scholar at Harvard Law School. Recently he was DCI Fellow at Stanford University. While teaching law he defended people on death row from the Caribbean before the Privy Council (UK), the highest court of Appeal for that region. He later became a tax partner at a global law firm and then a judge in the Tax Court in the UK. Kameel headed the Ex-Offenders Programme at The King's Trust Mosaic, which was created by HRH King Charles to provide mentoring and training to young offenders . He sat on the board of The King's Trust Mosaic. Kameel was born in Trinidad & Tobago. He studied at the London School of Economics and received a doctorate in law from McGill University, Montreal, Canada. When not lawyering he plays club cricket and listens to jazz. He likes to cook and spends the summer at his house in Italy on the Tuscan/Umbrian border. He is married and has two daughters; one a lawyer and the other a surveyor/urban planner. His interest lies in the rehabilitation of ex-offenders and in working together with similar minded people. He founded Project Remake a charity which provides jobs and entrepreneurial training to Prison leavers. ABOUT THE HOST Jeannette Linfoot is a highly regarded senior executive, property investor, board advisor, and business mentor with over 30 years of global professional business experience across the travel, leisure, hospitality, and property sectors. Having bought, ran, and sold businesses all over the world, Jeannette now has a portfolio of her own businesses and also advises and mentors other business leaders to drive forward their strategies as well as their own personal development. Jeannette is a down-to-earth leader, a passionate champion for diversity & inclusion, and a huge advocate of nurturing talent so every person can unleash their full potential and live their dreams. CONTACT THE HOST Jeannette’s linktree - https://linktr.ee/JLinfoot https://www.jeannettelinfootassociates.com/ YOUTUBE - https://www.youtube.com/@braveboldbrilliant LinkedIn - https://uk.linkedin.com/in/jeannettelinfoot Facebook - https://www.facebook.com/jeannette.linfoot/ Instagram - https://www.instagram.com/jeannette.linfoot/ Tiktok - https://www.tiktok.com/@brave.bold.brilliant Podcast Description Jeannette Linfoot talks to incredible people about their experiences of being Brave, Bold & Brilliant, which have allowed them to unleash their full potential in business, their careers, and life in general. From the boardroom tables of ‘big’ international businesses to the dining room tables of entrepreneurial start-ups, how to overcome challenges, embrace opportunities and take risks, whilst staying ‘true’ to yourself is the order of the day.Travel, Bold, Brilliant, business, growth, scale, marketing, investment, investing, entrepreneurship, coach, consultant, mindset, six figures, seven figures, travel, industry, ROI, B2B, inspirational: https://linktr.ee/JLinfoot

Tax Court looks at how to handle a situation where a partner deducted losses in excess of basis in a year no longer open to assessment and more.

This week we look at: IRS may stop putting “taxpayer may rely” statements on proposed regulations Tax Court rules partnership basis calculations are cumulative in nature and not stand-alone annual calculations under IRC §705  Latest speculations on what will get through Congress in 2025 - if anything

The IRS is winning more cases in the US Tax Court over companies' valuation of intangible assets, such as patents and trademarks, through transfer pricing. The wins have caught the attention of companies and practitioners as they mull the growing risks of transfer pricing, which governs transactions between related companies that are part of the same multinational group. Disputes between the IRS and companies such as Coca-Cola and 3M have showcased the agency's newfound ability to audit their positions and win in Tax Court when challenged. Both cases are being appealed. In addition, a new IRS policy to assess more penalties when documentation is lacking could make companies' transfer pricing positions much riskier than in the past, practitioners say, and taxpayers may have to start factoring that in. In this week's Talking Tax podcast, Bloomberg Tax reporter Caleb Harshberger spoke with Grant Thornton LLP Transfer Pricing Technical Leader Steve Wrappe and Greenberg Traurig LLP shareholder Sharon Katz-Pearlman about how the IRS has changed its approach and what additional funding from the 2022 Inflation Reduction Act means for taxpayers moving forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Taxpayers who engage in tax fraud face serious consequences, including steep penalties, endless assessment-periods, prolonged trials, reputational damage, and more. Mere allegations of fraud by the IRS can trigger these types of damaging outcomes. Cynics often argue that this is precisely the reason the IRS sometimes claims that fraud occurred in the first place. Fortunately for taxpayers, while alleging fraud is relatively easy, proving it can be hard for the IRS. Two recent Tax Court cases, analyzed in this article, demonstrate this reality. 

“If the decision-makers keep deciding that digital assets are just this fringe thing, there's going to be a missed opportunity”In this episode of Seize & Desist, our host, Aidan Larkin, explores tax compliance and enforcement in cryptocurrency with Miles Fuller, the director of government solutions at Taxbit, former senior counsel with the IRS Office of Chief Counsel and former Special Assistant United States Attorney.Miles shares his background in tax litigation with the IRS and provides insights into how Taxbit helps to trace criminal assets by combining on-chain and off-chain data to gain a comprehensive view of an individual's tax obligations.They also discuss the suitability of existing digital asset seizure legislation, the IRS' use of John Doe summons to obtain information from exchanges and the delicate balance between ensuring privacy in cryptocurrency transactions and preventing tax evasion before examining and speculating on the future of tax-related asset seizures.Timestamps00:00 - Special Announcement - Asset Reality's partnership with Taxbit03:00 - Miles' background with the IRS07:00 - Investigative tools and data aggregation in asset seizures10:30 - Tracing tools and address attribution in tax investigations11:30 - Integrating complex financial data for tax calculations13:00 - Streamlining financial investigations with crypto data tools16:00 - Challenges of detecting fraud in the virtual asset space21:00 - John Doe Summons in tax evasion investigations26:00 - Balancing privacy and compliance in blockchain transactions32:30 - Challenges of virtual asset seizures by governments41:00 - The future of tax compliance in the digital asset eraResources MentionedAsset Reality and Taxbit Partner to Enhance Digital Asset Seizure and ManagementDigital Asset Brokers: A Complete Guide to US Tax Compliance - Taxbit About our Guest:Miles Fuller is the Director of Government Solutions at Taxbit.As a former senior counsel with the IRS Office of Chief Counsel and former Special Assistant United States Attorney, Miles has a wealth of experience in tax-related asset seizures, having represented the IRS before the United States Tax Court, and has deep expertise in virtual asset tax and compliance issues, including regulatory guidance and policy development. Miles is also skilled in advanced investigation techniques for digital assets and has played a pivotal role in developing strategies to navigate the complexities of digital currency regulations.DisclaimerOur podcasts are for informational purposes only. They are not intended to provide legal, tax, financial, and/or investment advice. Listeners must consult their own advisors before making decisions on the topics discussed. Asset Reality has no responsibility or liability for any decision made or any other acts or omissions in connection with your use of this material.The views expressed by guests are their own and their appearance on the program does not imply an endorsement of them or any entity they represent. Views and opinions expressed by Asset Reality employees are those of the employees and do not necessarily reflect the views of the company. Asset Reality does not guarantee or warrant the accuracy, completeness, timeliness, suitability or validity of the information in any particular podcast and will not be responsible for any claim attributable to errors, omissions, or other inaccuracies of any part of such material. Unless stated otherwise, reference to any specific product or entity does not constitute an endorsement or recommendation by Asset Reality.

In this episode of The Million Dollar Flip Flops Podcast, Rodric Lenhart sits down with Charles Read, President and CEO of Get Payroll. Charles, a seasoned CPA and U.S. Tax Court practitioner, talks about the common pitfalls around payroll and compliance, revealing how businesses can navigate a changing landscape.Charles discusses the recent rule changes affecting independent contractors, the political influences on these regulations, and the potential impact on businesses. He also highlights the common mistakes in payroll processing - such as misclassification - that can lead to costly penalties.What You'll Hear in This Episode:The potential impact of regulatory changes on the gig economy Key payroll pitfalls and how to avoid themWhy accurate payroll processing is crucial to avoid penaltiesThe importance of professional payroll services for business ownersSome of the common hiring mistakes that can land you in hot waterQuote: "You're a successful businessman... but when the IRS comes calling, you're Beckham at second base. You're out of your league."– Charles ReadGuest Links:Get Payroll WebsiteCharles Read on LinkedInResources:Million Dollar Flip FlopsFollow Us on InstaIf you aren't 100% confident what your ‘next right move' is in your business…I may have a tool that can help. Take the Entrepreneurial Journey Quiz and find out which stage you are in and which areas to focus on.Take the quiz now: https://milliondollarflipflops.com/quiz/

Join me as I dive into two real estate focused Tax Court cases from summer of 2024. There's always something interesting to be learned when it comes to court cases.  Facebook group for Real Estate InvestorsFacebook group for Tax Professionals TC Summary 2024-17TC Summary 2024-13 [00:00:00] Welcome to Real Estate is Taxing, where we talk about all things real estate tax, and break down complex concepts into understandable, entertaining tax topics. My name is Natalie Kolodij, I'm your host, and I am so excited that you've decided to join me.[00:00:23] Hello. Hello everyone. Welcome to this week's episode. This summer has been a pretty good summer for tax court cases. And what I mean is that there have just been several that I specifically have enjoyed and thought were interesting. And that's because there have been a handful that relate to real estate. [00:00:45] [00:00:46] Now I love anything court related. I love reading true crime books. I love listening to the podcast. So for me, Reading tax court cases is extra exciting. But even [00:01:00] if you do not find that as cool as I do. These are still something that you should hold at least a little bit of interest in. The tax code itself is very rarely black and white. [00:01:12] There's a lot of room for interpretation. There's a whole lot of guidance and nuance that happens after the code is written. And the tax court results are really just one of those pieces of guidance. Reading these court cases. Really does give us fantastic insight to the way the courts have been leaning on some of these topics that are in that gray area. And when it comes to real estate, there's plenty of gray area that we love playing in with the tax code. So getting these more recent kind of thoughts from the tax court. Getting this feedback, seeing how they're viewing things. [00:01:55] This is invaluable. What I have for you guys today. [00:02:00] Is two court cases that are both tax court summary opinions from this summer. So these are super recent from July and August. And both are related to real estate. [00:02:11] The first case that I want to walk you guys through is from last month, this came out August 20, 24. This is TC summary, 2024 dash 17. Eason V commissioner. So this case was interesting because it deals with a topic that comes up pretty frequently when it comes to real estate in two different capacities. The first one being, if you pay for one of those 40, 50, $60,000 real estate guru courses, is it deductible? [00:02:45] And when is, or isn't it. And the other part of the question being, if you are new in real estate. When does your business actually begin? When are you open for business where you can start writing [00:03:00] off? All of your costs that are incurred. So those were the two big questions that came up in this case. [00:03:08] So this summary opinion relates to a couple who owned two rentals in 2016. One of them, they maintained as a rental. The second rental property they had sold by June of 2016. So at this point, they've got a little bit of real estate experience. They just actively got rid of half of their real estate business that existed, so to speak. [00:03:33] So they've got one rental left. [00:03:35] That same year. The taxpayer in this case. Lost his job. Close to the beginning of the year, the taxpayer lost his job. And the couple started looking into other ways they could supplement their income and other opportunities to help make up. For that last paycheck, they were used to getting. And one of the things they came across was real estate investing. So [00:04:00] they were already a little bit familiar with it and they had some experience with rentals, but they stumbled across an ad for a real estate course or courses that you could take. That would teach you how to invest presumably. In some capacity. The court case does not go into the details. Of exactly what was covered in that course or those courses. But what it does say is that the taxpayer and the spouse decided to invest in this And they spend $41,934 on two different courses from this same real estate. Uh, quote, education provider. So once they bought these courses, The couple, then went on to set up an S corporation. So they established an S Corp in July of 2016. And they got some business cards. They got some custom branded stationary. [00:05:00] But outside of that, Nothing else really happened. So there was no additional purchases of real estate. There were no proven efforts at marketing. For a real estate. [00:05:14] There was no proven efforts at advertising that they were in the market to buy real estate. Really not a whole lot else happened after they set up this S corporation and bought some business cards. Also worth noting. Is that by 2018. So within a year and a half from when they purchased these large expensive courses. The company through whom they had bought the courses. Went out of business. So another piece to this specific case that was taken into account by the tax court. Was the fact that this couple did anticipate having this ongoing support and resources. And all of this training and the moon and the sun and [00:06:00] everything else gurus promise you when you give them $40,000. And by 2018. None of it was there. [00:06:07] It had all disappeared. The company went under and they were now on their own. [00:06:12] So the year in question. For this couple's court case is 2016. So 2016 is the year when, as a recap, they had one rental property. They had sold off their other rental. Husband lost his job and they paid 40,000 plus dollars to accompany for real estate education. They then set up an S corporation, got some business cards and stationary. And that was the extent of the business operations. [00:06:44] in this case, there were a few key considerations. That were looked at. The first consideration. Is. Under code section 1 62. When is the taxpayer entitled to [00:07:00] deduct? An expense as a business expense that is ordinary and necessary. Like when is it rightfully able to be deducted? And a part of the wording to that code section. Is that it relates to ordinary or necessary expenses paid or incurred? During a tax year in quote, carrying on any trader business. Now a lot of businesses do not make money for their first few years. [00:07:29] That's not uncommon. A lot of businesses lose lots of money for multiple years that does not make or break whether or not someone is operating a business. However, in this case. There was all of the expense with none of the income, but also none of the proven effort to generate income. And none of the provable attempts. To actually continue to operate a business after buying the course, setting up the company, buying some [00:08:00] business cards that was the end of their effort. So for 2016, This couple reported over $40,000 of expenses as deductible business expenses. But when the court went back and looked, they really had no proof. That a good faith attempt was made. To actually run or operate or carry on a trader business. Part of the reason why. Is that it was never clearly defined what this couple's...

Strategies for limited partnerships and S corporations to minimize self-employment tax and net investment income tax following a 2023 tax court decision. The American College of Trust and Estate Counsel, ACTEC, is a professional society of peer-elected trust and estate lawyers in the United States and around the globe. This series offers professionals best practice advice, insights and commentary on subjects that affect the profession and clients. Learn more in this podcast.

On this episode of Adam Talks, tax attorney and IRA Financial's founder, Adam Bergman, Esq., discusses a recent Tax Court case centered around the importance of understanding the passive activity loss rules under Section 469 of the Code.

On today's episode of AdBits, tax attorney and IRA Financial's founder, Adam Bergman, Esq., discusses Rollins v. Commissioner, a 2004 Tax Court case, and why it was so monumental for self-directed retirement plans.

Check out this episode for information on upcoming conferences where you can find me as a guest speaker, along with some information on the Tax Court of Canada, including the role of "discoveries" in a tax hearing. RESOURCES DISCUSSED ON THIS EPISODETax Court of Canada - Your Day in CourtATAP CanadaAccountexHERE ARE SOME OTHER WAYS TO CONNECT WITH ME:My website! Email: thetaxchickpodcast@gmail.com@tax.chick (IG) LinkedInBe a "Tax Chick VIP" 

In this episode of Breaking Battlegrounds, we kick it off with Congressman Juan Ciscomani of Arizona's 6th Congressional District, who gives us the latest developments regarding the Trump assassination task force, the most recent job reports released, and his bipartisan affordable housing bill in Congress. Following this, Joe Bishop-Henchman from the National Taxpayers Union Foundation will discuss the impact of tariffs on the economy, the recent Chevron decision on businesses, and Biden's outrageous White House payroll. Finally, Alexander Raiken from the Ethics and Public Policy Center presents his analysis on how Donald Trump does not pose a threat to democracy. Tune in for an in-depth exploration of these pivotal issues shaping the political landscape.-www.breakingbattlegrounds.voteTwitter: www.twitter.com/Breaking_BattleFacebook: www.facebook.com/breakingbattlegroundsInstagram: www.instagram.com/breakingbattlegroundsLinkedIn: www.linkedin.com/company/breakingbattlegrounds-Show sponsors:Invest YrefyYrefy offers a secure, collateralized portfolio with a strong, fixed rate of return - up to a 10.25%. There is no attack on your principal if you ever need your money back. You can let your investment compound daily, or take your income whenever you choose. Make sure you tell them Sam and Chuck sent you!Learn more at investyrefy.com4Freedom MobileExperience true freedom with 4Freedom Mobile, the exclusive provider offering nationwide coverage on all three major US networks (Verizon, AT&T, and T-Mobile) with just one SIM card. Our service not only connects you but also shields you from data collection by network operators, social media platforms, government agencies, and more.Use code ‘Battleground' to get your first month for $9 and save $10 a month every month after.Learn more at: 4FreedomMobile.comDot VoteWith a .VOTE website, you ensure your political campaign stands out among the competition while simplifying how you reach voters.Learn more at: dotvote.vote-About our guests:Congressman Juan Ciscomani represents Arizona's 6th Congressional District in the United States House of Representatives. Juan and his family immigrated to the United States when he was a young boy. They established roots in Tucson, Arizona, where his father worked as a bus driver to give his children a shot at the American Dream. Growing up in a working class family taught Juan the value of hard work and the importance of a can-do attitude.Juan attended public schools in Tucson, Pima Community College and the University of Arizona. He worked his way through school with maintenance and service jobs until becoming the first in his family to graduate from college. After college, Juan worked for the University of Arizona and the Tucson Hispanic Chamber of Commerce before joining Arizona Governor Doug Ducey's administration as Senior Advisor and Vice-Chair of the Arizona-Mexico Commission. Juan focused on the issues of international trade and diplomacy, border security, and economic development.In 2022, Juan was elected to represent Arizona's new 6th congressional district, becoming the first naturalized American citizen from Mexico elected to the U.S. House of Representatives in Arizona history.In 2024, Juan was named the most bipartisan member from Arizona in the U.S. House of Representatives by the Lugar Center and McCourt School of Public Policy at Georgetown University Bipartisan Index.Juan often shares a conversation with his dad where his dad asked him:“Where else could we have our story? We come to the US, learn English, immerse in the culture, become US citizens, I drive a bus most of my life, and now my son is a United States Congressman. Where else in the world? Nowhere else, that's the American Dream.”Juan is determined to fight to keep that dream alive for others. Juan resides in Tucson with his wife, Laura, and their 6 kids — Zoe, Juan David, Kenny, Lily, Lucas, and Gloria.-Joe Bishop‐Henchman is Executive Vice President at the National Taxpayers Union Foundation, leading our work to protect taxpayer rights through research, litigation, and outreach. He has worked with elected officials and stakeholders to achieve major state‐level tax changes, advised on the interplay between federal and state policy changes, and authored over 100 studies on tax policy and tax law. Bishop‐Henchman is a class plaintiff in a major lawsuit against the Internal Revenue Service seeking refund of $300 million of illegally collected fees, was lead counsel in NTUF's Halstead Bead litigation that successfully prompted reform of Louisiana's complex local sales tax practices, and his brief in South Dakota v. Wayfair was cited twice by the U.S. Supreme Court majority opinion.Bishop-Henchman joined NTUF from the McDermott Will & Emery law firm, where he counseled clients on tax policy and compliance, and prior to that, 14 years at the Tax Foundation, where he co-authored 8 books on tax policy. He has testified to Congress seven times, in 36 state houses around the country, and on anti-corruption tax reform efforts in-person in Kyiv, Ukraine in 2023. He was educated at the University of California, Berkeley and received his J.D. from the George Washington University Law School and a certificate in International Legal Studies from the University of the Pacific, McGeorge and the University of Salzburg. He is admitted to practice law in New York, Maryland, the District of Columbia, and before the U.S. Supreme Court, the U.S. Tax Court, and the 4th, 5th, 6th, 9th, and D.C. Circuits.-Alexander Raikin is a friend on the show. He is a Visiting Fellow in Bioethics and American Democracy Program at the Ethics and Public Policy Center. His research focuses on the dignity of human life and end-of-life issues, especially on its impact on the field of medicine and broader ethical questions of social belonging. His writing has been widely cited in major publications such as The Atlantic and the New York Times and in academic journals in the United States, Canada, UK, and France. He wrote cover stories for National Review and The New Atlantis, while his other bylines include City Journal, Plough, and the Washington Free Beacon. Raikin frequently speaks on national radio and on major podcasts.Last year, Raikin was an inaugural Richard John Neuhaus Fellow at the Public Interest Fellowship and EPPC. He was a Tikvah Summer Fellow and a Killam scholar with Fulbright at American University. He graduated from Carleton University with a bachelor's degree in public policy. Raikin is a proud member of Kesher Israel synagogue and lives with his wife in Washington, D.C. Get full access to Breaking Battlegrounds at breakingbattlegrounds.substack.com/subscribe

A review of this week's major US international tax-related news. In this edition:  US House begins summer recess, Senate has additional week – DC Circuit Court of Appeals reverses Tax Court; FP's gain from inventory on US partnership disposition is foreign-source – IRS official comments on pending CAMT guidance – PTEP regulations in the ‘home stretch.'

My guest in this episode is John Hyre. John Hyre is an attorney, accountant, and investor. For the first seven years of his career, he worked at two large accounting firms and served as Tax Counsel for a Fortune 500 Company, gaining extensive experience in corporate taxes. For the past 18 years, he has run both an accounting practice and a tax law practice, working with small businesses, real estate investors, note investors, and self-directed retirement accounts. He has prepared thousands of tax returns, provided tax planning and reduction strategies, and successfully represented clients in IRS audits and Tax Court. Additionally, he has invested in mobile home parks, low-income rentals, and property flips. John is also a frequent speaker and author on the taxation of real estate and IRAs, and he has written three home study courses and numerous articles. Interview Links: John Hyre website; https://www.taxreductionlawyer.com/. Subscribe To Our Weekly Newsletter: The Wealth Dojo: https://subscribe.wealthdojo.ai/ Download all the Niches Trilogy Books: The 21 Best Cashflow Niches Digital: ⁠⁠https://www.cashflowninjaprograms.com/the-21-best-cashflow-niches-book⁠⁠ Audio: ⁠https://podcasters.spotify.com/pod/show/21-best-cashflow-niches⁠ The 21 Most Unique Cashflow Niches Digital: ⁠⁠https://www.cashflowninjaprograms.com/the-21-most-unique-cashflow-niches⁠⁠ Audio: ⁠https://podcasters.spotify.com/pod/show/21-most-unique-niches⁠ The 21 Best Cash Growth Niches Digital: ⁠https://www.cashflowninjaprograms.com/the-21-best-cash-growth-niches⁠⁠ Audio: ⁠https://podcasters.spotify.com/pod/show/21-cash-growth-niches Listen To Cashflow Ninja Podcasts: Cashflow Ninja ⁠https://podcasters.spotify.com/pod/show/cashflowninja⁠ Cashflow Investing Secrets ⁠https://podcasters.spotify.com/pod/show/cashflowinvestingsecrets⁠ Cashflow Ninja Banking ⁠https://podcasters.spotify.com/pod/show/cashflow-ninja-banking⁠ Connect With Us: Website: http://cashflowninja.com Podcast: http://resetinvestingsecrets.com Podcast: http://cashflowinvestingsecrets.com Podcast: http://cashflowninjabanking.com Substack: https://mclaubscher.substack.com/ Amazon Audible: https://a.co/d/1xfM1Vx Amazon Audible: https://a.co/d/aGzudX0 Facebook: https://www.facebook.com/cashflowninja/ Twitter: https://twitter.com/mclaubscher Instagram: https://www.instagram.com/thecashflowninja/ TikTok: https://www.tiktok.com/@cashflowninja Linkedin: https://www.linkedin.com/in/mclaubscher/ Gab: https://gab.com/cashflowninja Youtube: http://www.youtube.com/c/Cashflowninja Rumble: https://rumble.com/c/c-329875 --- Send in a voice message: https://podcasters.spotify.com/pod/show/cashflowninja/message

The IRS has focused on several different transactions in recent years, but its indignation now centers on certain positions taken by taxpayers in connection with Charitable Remainder Annuity Trusts (“CRATs”). This article describes a growing list of IRS efforts to stop what it deems abusive transactions involving CRATs.  These include a legal memo, an injunction lawsuit, two Tax Court battles, a Dirty Dozen listing, and, most recently, regulations proposing to categorize items as “listed transactions.”

In its effort to win conservation easement cases, the IRS has trotted out lots of different arguments over the years. Some were rejected by the Tax Court upon arrival, others gradually disappeared as taxpayers improved pre-donation documentation to avoid “technical” flaws, and a few still exist. One of the lingering challenges centers on the character of the property on which an easement is placed. This argument has been dubbed the “inventory issue,” and the IRS is now raising it frequently. These efforts have resulted in three recent Tax Court victories for the IRS. This article examines concepts in easement disputes, key participants, legal support for the “inventory issue,” and three pivotal cases thus far.

https://vimeo.com/943025614?share=copy https://www.currentfederaltaxdevelopments.com/podcasts  This week we look at: IRS releases Fact Sheet on disaster provisions for retirement accounts added by SECURE 2.0 Act DC Circuit reverses Tax Court ruling that IRS does not have assessment authority for failure to file a report under IRC §6038(b) (Form 5471) Electric vehicle final regulations issued Department of Justice begins process to move marijuana from Schedule I to Schedule III which would cause §280E to no longer limit deductions for cannabis businesses Lack of any written records on time President/COO spent on activities or even estimate time spent on qualified research activities doomed attempt to claim a credit under IRC §41(a)

This week we look at:IRS releases Fact Sheet on disaster provisions for retirement accounts added by SECURE 2.0 ActDC Circuit reverses Tax Court ruling that IRS does not have assessment authority for failure to file a report under IRC §6038(b) (Form 5471)Electric vehicle final regulations issuedDepartment of Justice begins process to move marijuana from Schedule I to Schedule III which would cause §280E to no longer limit deductions for cannabis businessesLack of any written records on time President/COO spent on activities or even estimate time spent on qualified research activities doomed attempt to claim a credit under IRC §41(a)An audio only version of this week's update can be streamed or downloaded below. A PDF of this week's slide and citation links can be downloaded below:2024-05-06 Current Federal Tax Developments

https://vimeo.com/940427506?share=copy https://www.currentfederaltaxdevelopments.com/podcasts/2024/4/28/2024-04-29-no-minimum-attention-required-for-supervisor-approval-of-penalties-per-tax-court This week we look at: Final regulations issued on credit transfer provisions of the Inflation Reduction Act Tax Court rules the law does mandate a minimum level of attention by a supervisor when approving a proposed penalty IRS announces the end of the Direct File pilot and will announce the next steps shortly

Final regulations on transfers of certain energy credits released, Tax Court rules on whether there's a minimum level of involvement with an exam before a supervisor can approve a proposed penalty and more.

This week we look at: Final regulations issued on credit transfer provisions of the Inflation Reduction Act Tax Court rules the law does mandate a minimum level of attention by a supervisor when approving a proposed penalty IRS announces the end of the Direct File pilot and will announce the next steps shortly Copyright 2024, Kaplan Financial Education

Fighting over when owners of limited partnerships must pay self-employment taxes has lasted nearly five decades. This struggle is attributable to several things, including the absence of applicable regulations, rapid evolution of business entities, and more. Uncertainty has caused taxpayers to claim disparate tax positions and triggered several big-dollar cases. This article, just one in a series, explores the relevant rules, a long list of arguments advanced by taxpayers and the IRS in two pending cases, and the recent Tax Court ruling that it must apply a “functional test” to determine whether a partner in a limited partnership meets the relevant exemption.

https://vimeo.com/929341969?share=copy https://www.currentfederaltaxdevelopments.com/podcasts/2024/3/31/2024-04-01-tax-court-reverses-position-on-validity-of-conservation-easement-regulation  This week we look at Tax Court reverses position on validity of a regulation it had upheld four years ago US Supreme Court hears oral arguments in case involving estate tax value of a corporation that received life insurance to redeem the majority shareholder's estate IRS Criminal Investigation Divisions announces update on COVID relief related investigations and convictions

Tax Court reverses position on the validity of conservation easement regulations, Supreme Court hears a closely held corporation valuation case and more

This week we look at Tax Court reverses position on validity of a regulation it had upheld four years ago US Supreme Court hears oral arguments in case involving estate tax value of a corporation that received life insurance to redeem the majority shareholder's estate IRS Criminal Investigation Divisions announces update on COVID relief related investigations and convictions

William McRae of Cleary Gottlieb discusses the U.S. Tax Court's decision in YA Global Investments v. Commissioner and what it means for the private equity sector. For additional coverage, read these articles in Tax Notes:Tax Pro Questions Tax Court's Dealer Analysis in YA GlobalTax Pros Weigh Impact of YA Global on Fund IndustryYA Global Footnote Shouldn't Be OverlookedCayman Islands Hedge Fund Liable for Tax Bill of Over $57 MillionFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Everyone knows that IRS is struggling to timely process and audit Employee Retention Credit (“ERC”) claims. What many people do not realize, though, is that the Tax Court issued a decision in January 2024 that might affect timing issues. This article, another in a series, discusses ERC guidance, the three-year and five-year assessment periods under current law, key Tax Court cases addressing the impact of fraud by return preparers on assessment periods of taxpayers, the broad definition of preparers, and potential effects on well-intentioned taxpayers filing improper ERC claims

https://vimeo.com/924422473?share=copy https://www.currentfederaltaxdevelopments.com/podcasts/2024/3/17/2024-03-18-last-call-to-enter-erc-voluntary-disclosure-program This week we look at: FinCEN gives formal notice of appeal of CTA BOI case Deadline rapidly approaching for entering first ERC voluntary disclosure program Arizona lawmakers write the IRS about tax status of 2023 state rebates Court of Appeals finds it is barred from hearing appeal of Tax Court dismissal of small case

The United States Tax Court ruled in a Feb. 20 decision that a taxpayer was correct to include bond issuance costs in eligible basis for a 4% low-income housing tax credit (LIHTC) property in New York City. That decision ran counter to more than two decades of practice that followed Internal Revenue Service (IRS) guidance from as far back as 2000 that said including such costs was disallowed. In the latest installment of Tax Credit Tuesday, Michael Novogradac, CPA, and Nicolo Pinoli, CPA, discuss the details of the case in question before the court as well as the possible ramifications of the decision, including what the IRS could do now and what this decision could mean for credit allocating agencies, developers, investors and others who build multifamily affordable rental housing using LIHTCs.

This week we look at: More BOI resources from CAMICO made available by NJCPA District Court refuses to stay FBAR proceeding to await Tax Court result partially due to the age of the taxpayer IRS announces program to go after corporate jet personal usage The state of Arizona sues the IRS over tax status of state tax rebate.