Transactions involving the disposition of partnership property or partnership interests can trigger rules that limit business interest expense deductions. Section 163(j) of the Internal Revenue Code generally...
Interested in knowing what other partners are saying about how commercial lease agreements are evolving? Access exclusive market intelligence about private commercial lease agreements, as only told by...
The seller usually wants assurances that a buyer will be able to fund an acquisition at the closing, particularly if the closing is subject to a lengthy interim period between signing and closing. If a...
A company that receives a warning letter from the Food and Drug Administration (FDA) is on FDA's radar screen. In addition to responding appropriately to any actual or potential violations indicated...
We just added Arbitration Q&A content to Practical Guidance’s State Law Comparison Tool! Compare state laws on arbitration both pre-dispute and once a dispute arises across five key arbitration...
As we enter the 2022 tax filing season, still struggling with COVID-related mail delays and IRS service center reductions, best practice requires practitioners to closely track client tax filings and their IRS deadlines. Of note is Boechler, P.C. v. Commissioner of Internal Revenue, an Eighth Circuit decision for which SCOTUS was petitioned to determine whether “equitable tolling,” allowing the courts to excuse missed deadlines, depending on the situation, is available for a statutory deadline. SCOTUS heard oral arguments for the case on January 12 which appear to lean in the taxpayer’s favor, preventing the tax levy. Boechler’s particular question is whether the time limit in I.R.C. Section 6330(d)(1) (Notice and Opportunity for Hearing Before Levy), giving the taxpayer 30 days to petition the Tax Court for review, is a jurisdictional requirement or a claim-processing rule.
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