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Wednesday, October 27, 2021

Tax Court Dissects Complex Acquisition Transaction With Senior and Subordinated Debt Characterization in Issue (10/27/21)

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In  Tribune Media Co. v. Commissioner , T.C. Memo. 2021-122,  here , issued yesterday, the Tax Court addressed a complex acquisition of the ...
Tuesday, October 19, 2021

Freeman Law International Tax Symposium on 11/18 and 11/19 (10/19/21)

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The following international tax program may be of interest to FTPB readers:  Freeman Law International Tax Symposium on November 18 and 19  ...
Monday, October 4, 2021

District Court Enforces Summons to Delaware Dept of Insurance for Micro-Captive Information (10/4/21)

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The district court has enforced the IRS summons issued to the Delaware Department of Insurance (“DDOI”) for information and documents on abo...
Thursday, September 30, 2021

Supreme Court Grants Cert on Issue of Whether CDP 30-day Time Limit is Jurisdictional (9/30/21)

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The Supreme Court granted the petition for writ of certiorari in Boechler v. Commissioner , 2020 U.S. App. LEXIS 23306 (8 th Cir. 2020) to ...
Tuesday, September 28, 2021

More on Footnotes (9/28/21)

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In prior editions of my Federal Tax Procedure Book, I offered Appendix C as a digression on footnotes.  I posted a blog entry with that Appe...
Sunday, September 26, 2021

DOJ OIG Reports on DOJ Tax Expert Contracting (9/26/21)

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The DOJ Office of the Inspector General (“OIG”) issued this press release of a new report:  DOJ OIG Releases Report on the Audit of Certain ...
Wednesday, September 22, 2021

IRS Enjoined from Enforcing Tax Shelter Notice Requirement for Material Advisor for Microcaptive Transactions (9/22/21)

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In CIC Services, LLC v. IRS , 583 U.S. ___ (2021), here , the Court held that the Anti-Injunction Act (§ 7421(a)) did not preclude a contest...
Monday, September 20, 2021

Revised Federal Tax Procedure (2021 Student Ed.) with Links (9/20/21)

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I have posted a revised version of Federal Tax Procedure (2021 Student Ed.) on SSRN, here https://ssrn.com/abstract=3897432 .  The principa...
Saturday, September 18, 2021

Court Sustains Almost $350 Million Jeopardy Assessment Arising from Sham / Bullshit Tax Shelter (9/18/21)

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In Kalkhoven v. United States , 2021 U.S. Dist. LEXIS 175844 (E.D. Cal. 9/15/21), CL here , the Court sustained the IRS’s jeopardy assessmen...
Wednesday, September 8, 2021

On Complexity and Algorithms in Tax Administration (9/8/21)

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The Procedurally Taxing Blog has a good post this morning, Bob Probasco (Guest Blogger), Complications from Extensions and Unprocessible Ret...