Tax Law

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PPL Corp. & Subsidiaries v. Comm'r, 2010 U.S. Tax Ct. LEXIS 31 (T.C. Sept. 9, 2010)
Posted on 11 Nov 2010 by LexisNexis Tax Center

The IRS had declared a deficiency in 1997 federal income tax paid by PPL Corporation, the common parent of a group filing consolidated returns, denying its refund claim. At issue inter alia was the correctness of an IRS claim that a "windfall tax"... Read More

Bilski v. Kappos, 2010 U.S. LEXIS 5521 (U.S. June 28, 2010)
Posted on 25 Aug 2010 by LexisNexis Tax Center

The Supreme Court, for the first time since the Federal Circuit's decision in State Street Bank & Trust Co. v. Signature Fin. Group Inc. , 149 F.3d 1368 (Fed. Cir. 1998) , addressed the proper standard for determining whether a claimed process... Read More

Canal Corp. v. Comm'r, 2010 U.S. Tax Ct. LEXIS 25 (T.C. Aug. 5, 2010)
Posted on 10 Sep 2010 by LexisNexis Tax Center

The Service determined a $183,458,981 deficiency in the Chesapeake Corporation's Federal income tax, asserting that Chesapeake owed a $36,691,796 substantial understatement of income tax penalty under section 6662(a) for 1999. Chesapeake's subsidiary's... Read More

River Garden Retirement Home v. Franchise Tax Bd., 2010 Cal. App. LEXIS 1146 (Cal. App. 1st Dist. July 15, 2010)
Posted on 29 Jul 2010 by LexisNexis Tax Center

The California Franchise Tax Board's decision to recoup the Cal Rev & Tax Code § 24402 dividends received deduction against a taxpayer was proper where Board proceeded with proper authority to remedy Commerce Clause violation infecting Cal... Read More

CenturyTel, Inc. v. Dep’t of Revenue, 2010 Ore. Tax LEXIS 222 (Or. T.C. Aug. 9, 2010)
Posted on 16 Sep 2010 by LexisNexis Tax Center

The taxpayer, domiciled outside of Oregon, and its subsidiaries were inthe wireline and wireless telecommunications business. When the taxpayer executed transactions related to the sale of stock, it was, for practical purposes, no longer engaged in wireless... Read More