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Service prevails before Tax Court in self-employment tax case

Fox Rothschild LLP
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USA
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January 21 2013

In a recent memorandum decision of the Tax Court in Howell, TCM 2012-303, a couple was held liable for a deficiency in self-employment taxes, plus

Tax court finds shareholder's leasing of cell towers to S corporation was a passive activity despite corporation's grouping such leasing activities as part of the conduct of a trade or business

Fox Rothschild LLP
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USA
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January 17 2013

Petitioner-taxpayer leased land and telecommunication towers to his wholly owned S corporation, in exchange for a percentage of the Company's

Department of Justice, Civil Tax Division, awarded summary judgment to collect civil penalties against taxpayer for willfully failing to FBAR reports for two years

Fox Rothschild LLP
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USA
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November 19 2012

The United States District Court for the District of Utah, Central Division, on November 8, 2012, Judge Nuffer, granted the United States its motion for summary judgment for the taxpayer-defendant’s, Jon Mc Bride, willful failure to report his interest in foreign bank accounts in contravention of 31 U.S.C. Section 5314 for the years 2001 and 2002

Recent amendments to Tax Court rules of practice and procedure on work product and discoverability of expert witness reports and communications to petitioner's counsel

Fox Rothschild LLP
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USA
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October 12 2012

Chief Judge Michael B. Thornton, by press release of July 6, 2012, announced that the United States Tax Court has adopted amendments to its Rules of Practice and Procedure

Federal District Court for Arizona rejects taxpayers' calculation of stock basis attributable to sale of stock from various insurance companies that had previously converted from a mutual based to a stock based company: Dorrance v. United States, 110 AFTR

Fox Rothschild LLP
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USA
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July 13 2012

A district court in Arizona has rejected cross motions for summary judgement filed by the taxpayers and the government in a tax refund case involving the amount of basis that could be established with respect to "equity" type rights that a policyholder had in several life insurance policies issued by a mutual insurance company which was demutualized into a stock company

Eighth Circuit Court of Appeals gives service a major victory to recharacterize distributions from an s corporation to its shareholder(s) as wages for FICA purposes

Fox Rothschild LLP
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USA
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July 8 2012

In David E. Watson, P.C. v. Commissioner, 668 F.3d 1008 (8th Cir. 2012), aff’g 757 F. Supp. 2d 877 (DC Iowa) the Eighth Circuit affirmed a federal district court of Iowa’s decision recharacterizing a substantial portion of dividend distributions made by an S corporation to its sole shareholder as wages for FICA purposes

Tax Court Memorandum decision denies charitable deduction for highly valued real estate in Joseph Mohamed, Sr., TC Memo 2012-152

Fox Rothschild LLP
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USA
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June 4 2012

In a recently issued Tax Court Memorandum decision written by Judge Holmes the taxpayers were denied charitable deductions for millions of dollars in value of real property which they contributed by donation in 2003 and 2004 for the benefit of three charities as remaindermen of a charitable remainder unitrust

Third Circuit reverses tax court and holds taxpayers received tax-exempt interest on deferred payments from the Pennsylvania Department of Transportation negotiated as part of an out-of-court settlement

Fox Rothschild LLP
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USA
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April 13 2012

The Third Circuit, in partially reversing the Tax Court, in DeNaples v. Commissioner, 109 AFTR 2d 2012-1419 in a three judge panel opinion filed on March 19, 2012, held that two couples were in receipt of tax-exempt interest income under 103 with respect to installment payments made under an out-of-court settlement agreement with the State of Pennsylvania that arose out of an eminent domain proceeding

Commissioner prevails in imposing deficiency with respect to at-risk recapture in Roy Zeluck, TC Memo 2012-98

Fox Rothschild LLP
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USA
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April 8 2012

Taxpayer invested $310,000 in an oil and gas partnership in 2001 consisting of cash of $110,000 and a subscription note issued by the taxpayer obligating him to pay $200,000 at the stated maturity date of December 31, 2009

Case summary:1982 East, LLC v. Commissioner of Internal Revenue

Fox Rothschild LLP
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USA
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January 20 2012

The U.S. Tax Court, in 1982 East, LLC v. Commissioner of Internal Revenue, T.C. Memo. 2011-84 (2011), again upheld the disallowance of a charitable deduction under section 170 of the Internal Revenue Code for the contribution of a historic preservation easement