Is Tax Litigation Irrational?

According to Supreme Court barrister Robert A. Long it may well be. Our beloved world of tax litigation had its 15 minutes of fame this morning as the first argument challenging President Obama's health care law involved the applicability of the Anti-Injunction Act. Probably best known among tax...

Proposed Regs Clarify Charitable Hospital Organization Requirements

The Patient Protection and Affordable Care Act added IRC Section 501(r) , which imposes detailed conditions on a hospital organization seeking exemption under IRC Section 501(c)(3) . In addition to satisfying the requirements of IRC Section 501(c)(3) , hospital organizations must also meet the: community...

Obamacare Survives Under Power of Taxation

In the Supreme Court's decision in National Federation of Independent Business v. Sebelius, 132 S. Ct. 2566 (June 28, 2012) , the Court determined the constitutionality of the most controversial provision of the Patient Protection and Affordable Health Care Act of 2010 ( P.L. 111-148 , also known...