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Thursday, February 29, 2024

Garland v. Cargill-Comments on Briefs and Oral Argument (2/29/24)

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Yesterday, the Supreme Court held oral argument in Garland v. Cargill (No. 22-976 docket here , oral argument audio here , and transcript o...
Tuesday, February 27, 2024

District Court Holds Indicatively While Case on Appeal That Remand of FBAR Willful Penalty to IRS Did Not Vacate the Timely Assessments (2/27/24)

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   In   United States v. Kerr   (D. AZ Dkt O. 2:19-CV-05432 Order dtd 2/23/24), TN   here   and CL   here , the district court ruled   indic...
Saturday, February 24, 2024

Grossly Overvalued Conservation Easement Disallowed in Full and Gross Valuation Misstatement Penalty Applied (2/24/24)

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In Oconee Landing Property, LLC v. Commissioner , T.C. Memo. 2024-25 (2/21/24), GS  here , the Court (Judge Lauber) denied the charitable co...
Friday, February 23, 2024

Tax Court Denies WB Claim Made Contemporaneously With Target Taxpayer’s Voluntary Disclosure (2/23/24)

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In Whistleblower 14376-16W v. Commissioner , T.C. Memo. 2024-22, GS here , the Court held that the Whistleblower (“WB”) was entitled to no r...
Thursday, February 22, 2024

Oral Argument in Corner Post on Whether Procedural Challenges to Regulations Are Subject to § 2401(a)’s Six-Year Statute of Limitations (2/21/24; 4/6/24)

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I previously included in another blog an introduction to Corner Post v. Board of Governors of the Federal Reserve System (Sup. Ct. Case No....
Tuesday, February 20, 2024

Court Holds that Untimely Refund Claim by Amended Return Stating a Different Legal Basis Does Not Relate Back to Timely Refund Claim by Amended Return (2/20/24)

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In American Guardian Holdings, Inc. v. United States (N.D. Ill. Case 23 C 1482 Memo Op. & Order 2/7/24), GS here and CL here , the dis...
Wednesday, February 14, 2024

Sixth Circuit Affirms Summary Judgment on FBAR Willful Penalty on Conduct Objectively Reckless (2/14/24)

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I report this morning on   United States v. Kelly , 92 F.4th 598 (6th Cir. 8/8/24), CA6   here   and GS   here .   Kelly   affirms the distr...
Monday, February 12, 2024

Experts in Technical Area (FDA) Caution Supreme Court About Problems in Overruling Chevron Deference (1/12/24)

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I recently wrote a blog on the bad effects of eliminating Chevron deference in a specific context—the § 6751(b) regulations bringing clarity...
Thursday, February 8, 2024

ATL Article on Tax Structuring on Sale of MLB Team (2/8/24)

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I picked this up today involving the type of planning that may keep well-paid tax controversy specialists busy in the future. Steven Chung, ...
Tuesday, February 6, 2024

Tax Court Denies Petitioner Summary Judgment on Transferee Liability (2/6/24)

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In Meyer, Transferee v. Commissioner , T.C. Memo. 2024-15 (2/5/24), TC Dkt Entry # 44, here , TN here , and GS here , the Court denied the p...