Tax Law

Recent Posts

Tax Court: Premature FPAA on Computational Items Invalid, Jurisdiction Denied
Posted on 29 Mar 2012 by Asbury Law Firm

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... Read More

Tags: single tax-advantaged transaction , FPAA , Final Partnership Administrative Adjustment , Asbury Law Firm , Jurisdiction , partnerships , tax court , lack of jurisdiction , Rawls Trading v. Commissioner , TEFRA , Federal Taxation

Sutherland Legal Alert: U.S. Tax Court Issues Opinion in Tigers Eye Regarding Golsen Rule and TEFRA Proceedings
Posted on 16 Mar 2012 by Sutherland Asbill & Brennan LLP

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... Read More

Tags: Tiger Eye Trading v. Commissioner , inevitable reversal , partnership item , Golsen v. Commissioner , Sutherland Asbill , binding precedent , tax court , outside basis , partnership audits , Tax Equity and Fiscal Responsibility Act , TEFRA

Tax Court: Premature FPAA on Computational Items Invalid, Jurisdiction Denied
Posted on 29 Mar 2012 by Asbury Law Firm

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... Read More

Tags: single tax-advantaged transaction , FPAA , Final Partnership Administrative Adjustment , Asbury Law Firm , Jurisdiction , partnerships , tax court , lack of jurisdiction , Rawls Trading v. Commissioner , TEFRA , Federal Taxation

Sutherland Legal Alert: U.S. Tax Court Issues Opinion in Tigers Eye Regarding Golsen Rule and TEFRA Proceedings
Posted on 16 Mar 2012 by Sutherland Asbill & Brennan LLP

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... Read More

Tags: Tiger Eye Trading v. Commissioner , inevitable reversal , partnership item , Golsen v. Commissioner , Sutherland Asbill , binding precedent , tax court , outside basis , partnership audits , Tax Equity and Fiscal Responsibility Act , TEFRA