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Tax Court Announcement: E-Filing Requirement is Effective July 1st

The Tax Court's May 6th Announcement requires that most documents, with certain exceptions, filed by represented parties in the Tax Court in open cases in which the petition is filed on or after July 1, 2010. The Announcement document is attached. For additonal background and information, tune...

Henricus v. Comm’r.: a Trader v. Investor Déjà vu

It seems like as of late the Tax Court is set on slamming every person that comes through its doors claiming a trader status. It feels like it was yesterday when I talked about the Richard Kay case on this blog . There I alluded that a taxpayer who seemed to fall within the category of what most people...

Sutherland Legal Alert: U.S. Tax Court Issues Opinion in Tigers Eye Regarding Golsen Rule and TEFRA Proceedings

By Tom Cullinan , Joe DePew , and Shane Lord , Sutherland Asbill & Brennan LLP We rarely send out Legal Alerts about the so-called "TEFRA" rules that govern partnership audits and litigation because so few people would read them. In Tigers Eye , however, the Tax Court took a noteworthy...

Tax Court: Premature FPAA on Computational Items Invalid, Jurisdiction Denied

There are few areas of the tax code as complex and potentially confusing as the rules for TEFRA partnership proceedings. Even the most steely-eyed tax pros wince at the details. Nonetheless, TEFRA is at the heart of many of the transactions that the IRS has challenged over the course last decade and...

4th Circuit: Denial of Transferee Liability for Intermediary Transaction Tax Shelter Affirmed

The Fourth Circuit Court of Appeals affirmed the Tax Court's decision in favor of four taxpayers who were alleged to have participated in what the IRS describes as an Intermediary Transaction tax shelter. The majority opinion, authored by Circuit Judge Davis, held that the Tax Court properly identified...

Tax Court: Donation of Conservation Easement Upheld

The Tax Court affirmed the proposition that a conservation easement is still a Congressionally sanctioned charitable contribution under section 170 . Conservation easements and the corresponding charitable contribution deduction for the donation of such easements has been a topic of heightened scrutiny...

Tax Court Finds IRS Compliance Officer Liable for Civil Fraud Penalty

Readers interested in the risks of being audited with respect to income tax noncompliance arising from foreign assets (particularly financial accounts) often ask what it takes for the IRS to prove fraud. I am aware of no standard litmus test of civil tax fraud that will identify, particularly for laymen...