The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: Read more ››
Meiliyane Blog
IRS Issues Proposed Regulations under Section 6751(b)
When is Written Managerial Approval Required? In 1998, Congress sought to provide additional protections to taxpayers through passage of the Internal Revenue Service Restructuring and Reform Act (the “Act”). Buried Read more ››
Texas Tax Roundup March 2023
Hiya folks, and welcome back to another Texas Tax Roundup! March 2023 brought us a lot of administrative action, especially for Texas sales or use tax. Let’s get started! Rules Read more ››
Tax Court in Brief | Estate of Hoenshied v. Commissioner | Anticipatory Assignment of Income, Charitable Contribution Deduction, and Qualified Appraisals
The Tax Court in Brief – April 3rd – April 7th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
Accredited Investor Status in Federal Securities Law
The term “accredited investor” is frequently heard in the field of financial investing. But many investors lack an in-depth understanding of the implications of accredited investor status or how it Read more ››
Section 501(c)(3) Dissected: IRS Issues Detailed Guidance on Exempt Purposes
On March 17, 2023, the IRS Exempt Organizations and Government Entities Division published two Technical Guides: (1) TG 1 Instrumentalities of the United States, Government Corporations, and Federal Credit Unions; Read more ››
Texas Mixed Beverage Taxes | Freeman Law
The state of Texas imposes two taxes on alcoholic beverages that impact holders of certain permits under the Texas Alcoholic Beverage Code. These taxes are the mixed beverage gross receipts Read more ››
IRS: Basis Adjustments Apply to CFC Mid-Year Distributions to Prevent Section 961(b)(2) Gain
PLR 202304008: Taxpayer Does Not Have Section 961(b)(2) Gain for Mid-Year Distributions Introduction to Section 961 and Mid-Year Distributions For years, there has been a longstanding question under the subpart Read more ››
Tax Court in Brief | Estate of Kalikow v. Comm’r | Estate Tax Taxation and Deductions and QTIP Trust
The Tax Court in Brief – March 6th – March 10th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
Tax Court in Brief | Dawveed v. Comm’r | Restitution-Based Assessment and Collection Due Process
The Tax Court in Brief – March 6th – March 10th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
