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Valero Energy Corp. v. United States, 2009 U.S. App. LEXIS 13050 (7th Cir., June 17, 2009)

Tax practitioner-client privilege under 26 U.S.C.S. § 7525(a)(1) did not apply to documents sought by the IRS that contained financial data, tax liability estimates, and other accounting advice. The exception under § 7525(b) for documents promoting...

LexisNexis Tax Center
Bakersfield Energy Partners LP et al. v. Commissioner, 2009 U.S. App. LEXIS 12932 (9th Cir., June 17, 2009)

Judgment in favor of taxpayers was affirmed because although the U.S. Supreme Court in Colony, Inc. v. Comm'r, interpreted a 1939 version of the tax code, it's holding was still controlling because Congress did not change the language in the body...

LexisNexis Tax Center
Mayo Foundation for Medical Education and Research et al. v. United States, 2009 U.S. App. LEXIS 12640 (8th Cir., June 12, 2009)

Medical residents who received stipends for services at hospitals and clinics did not qualify for the student exemption from FICA taxes under 26 U.S.C.S. § 3121(b)(10); Treas. Reg. § 31.3121(b)(10)-2, which barred persons who worked full-time...

LexisNexis Tax Center
Michael W. Keller et al. v. Commissioner, 2009 U.S. App. LEXIS 12043 (9th Cir., June 3, 2009)

Commissioner of Internal Revenue did not abuse its discretion when it rejected the taxpayers' offer of compromise because it was substantially lower than what reasonable collection potential calculation showed they could afford to pay and imposition...

LexisNexis Tax Center
Klamath Strategic Investment Fund et al. v. United States, 2009 U.S. App. LEXIS 10456 (May 15, 2009)

In a suit filed under 26 U.S.C.S. § 6226 by two investment fund partnerships seeking a readjustment of partnership items, a complex series of loan transactions were properly disregarded for tax purposes because, under the economic substance doctrine...

LexisNexis Tax Center
Lawrence S. Berger; Realty Research Corporation, Appellants v. Internal Revenue Service; Dept. of the Treasury, 288 Fed. Appx. 829; 2008 U.S. App. LEXIS 17256 (3rd Cir., August 11, 2008)

IRS did not violate the FOIA or the Privacy Act when it refused to disclose time records of IRS agent who conducted civil investigation of a corporation and an individual. The time records were exempt from disclosure under 5 U.S.C.S. § 552(B)(6)...