Tag: Tax Court


IRS Flaunts Recent Tax Court Victory in Microcaptive Arena

By: Heather L. Marello, Esq. In a recent press release, IRS is again urging participants in abusive microcaptive insurance arrangements to cease participation in such transactions.  This message comes after the Service’s recent win in the U.S. Tax Court in Caylor Land & Dev. v. Commissioner, T.C. Memo 2021-30 (2021).  This win marks the fourth major victory in this area,

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The Tax Court Reminds Foreign Corporations of the Disastrous Consequences of Failing to File Forms 1120-F U.S. Income Tax Returns

By: Heather L. Marello, Esq. I.R.C. § 6012(a)(2) imposes an income tax return filing requirement on “every corporation subject to taxation under subtitle A.”  The Treasury Regulations clarify that a foreign corporation is not exempt from U.S. taxation if it is engaged in a U.S. trade or business, even if it has no effectively connected U.S. income or its income

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Introduction to IRS Appeals and the U.S. Tax Court (Part 3)

By: Michael J. Tedesco, Esq. Introduction to IRS Appeals IRS Appeals is a separate branch of the IRS, whose purpose is to resolve tax controversies between the IRS and taxpayers through an informal, administrative process, fairly and impartially, without litigation. IRS Appeals has substantive experts in many of the same areas as the IRS (i.e. designated personnel who deal only

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The Lifecycle of a Tax Controversy (Part 1)

By: Michael J. Tedesco, Esq. We find that accountants and taxpayers are often unfamiliar with certain aspects of the typical tax controversy (i.e. how a tax matter moves through assessment, Tax Court/Appeals and Collections). We have put together a series of articles moving through “The Lifecycle of a Tax Controversy”. What follows is the first part of what will be

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