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Showing posts with label Valuation. Show all posts
Showing posts with label Valuation. Show all posts
Thursday, September 11, 2025

Do Mixed Questions of Fact and Law Have Component Facts and Law for § 7491(a) Purposes? (9/11/25)

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I address today what may seem to be a fairly mundane issue, but in some contexts might be important. Readers may already be familiar with § ...
Wednesday, July 16, 2025

Tax Court Rejects a Bullshit Tax Shelter False Valuation Claim with Warning of Sanctions for Taxpayers, their Counsel, and Expert Witness Proffering the Bullshit (7/16/25; 9/10/25)

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Note a significant addition was made on 9/10/25 @ 5:30pm at end of this blog entry. I write today on a “dictated” oral decision at the concl...
Sunday, April 14, 2024

Tax Court Judge Lauber Denies Petitioner Motion for Summary Judgment Rejecting Fraud Penalties in Allegedly Abusive SCE Case; Some Background (4/14/24)

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In North Donald LA Property LLC et al. v. Commissioner (Order T.C. Dkt. 24703-21 #140 4/10/24), TA here and TC Dkt here *, a syndicated co...
Saturday, August 20, 2022

Transfer Pricing: Finite Valuation and Ranges (8/20/22)

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          I have just started reading a tax, more or less, history, at least anecdotal history. Michael Keen, & Joel Slemrod, Rebellion,...
Saturday, July 9, 2022

4th Circuit Holds the Tax Partnership Receiving an Administrative Summons is Different Than its Representative for Purposes of § 7602(d) (7/9/22; 7/12/22)

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In Equity Inv. Assocs., LLC v. United States , 40 F.4th 156 (4th Cir. July 8, 2022), CA 4 here  and GS here , the Court held that, for purpo...
Monday, November 23, 2020

More Coca-Cola - On Transfer Pricing and Blocked Income Regulation (11/23/20)

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I recently wrote on burden of proof issues in The Coca-Cola Company v. Commissioner , 155 T.C. ___, No. 10 (2020), here .  Tax Court (Judge ...
Thursday, November 19, 2020

Tax Court (Judge Lauber) Issues Significant Transfer Pricing Decision in Coca-Cola; Burden of Proof Issues (11/19/20; 11/25/20)

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Yesterday, the Tax Court decided The Coca-Cola Company v. Commissioner , 155 T.C. ___, No. 10 (2020), GS  here , a transfer pricing company ...
Monday, October 26, 2020

Two Updates on Syndicated Conversation Easements (10/26/20)

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I report in brief two recent developments in syndicated easement cases that have been the focus of so much IRS audit and investigation activ...
Friday, June 26, 2020

IRS Offers to Settle Abusive Syndicated Conservation Easement Shelters Pending in Tax Court (6/26/20)

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In IR-2020-13, here , the IRS announces that it will offer to settle Conservation Easement Syndication shelters of the BS genre that are cur...
Monday, June 8, 2020

Publication in ABA Tax Lawyer Townsend Burden of Proof Article (6/8/20)

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The ABA Tax Lawyer publication has published my article:  John A. Townsend, Burden of Proof in Tax Cases: Valuation and Ranges—An Update , 7...
Monday, December 9, 2019

Townsend Article on Burden of Proof and Valuation in Tax Cases (12/9/19)

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Caveat:  The ABA Tax Lawyer publication has published my article:  John A. Townsend,  Burden of Proof in Tax Cases: Valuation and Ranges—An ...
Friday, November 8, 2019

The Notice of Deficiency (11/8/19)

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Tax Procedure fans should follow Bryan Camp's weekly offerings on the Tax Prof Blog, here (the link is to the cover page for the blog)....
Tuesday, October 21, 2014

Thoughts on Estate of Elkins and Valuations (10/21/14)

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I write today on the Fifth Circuit's opinion in Estate of Elkins v. Commissioner , ___ F.3d ___, 2014 U.S. App. LEXIS 17882 (5th Cir. 20...
Wednesday, November 20, 2013

Tax Court Rejects Unusual Path to Admission of Expert Testimony (11/20/13)

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In Estate of Tanenblatt v. Commissioner , T.C. Memo. 2013-263, here , the Tax Court excluded an expert witness report that the petitioner at...