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IRS Issues Final Regulations on Deduction for Certain Fines and Penalties Under Section 162(f)

USA - January 20 2021 On January 12, 2021, the IRS issued final regulations on Internal Revenue Code Section 162(f), as amended by the TCJA, concerning the deduction of…

Richard A. Nessler

IRS Issues Final Regulations on Deduction for Certain Fines and Penalties Under Section 162(f)

USA - January 20 2021 On January 12, 2021, the IRS issued final regulations on Internal Revenue Code Section 162(f), as amended by the TCJA, concerning the deduction of…

Richard A. Nessler

Focus on Tax Controversy - November 2020

USA - November 19 2020 In the wake of the recent economic downturn caused by the COVID-19 pandemic, there will likely be a sharp rise in bankruptcy filings by businesses…

Richard A. Nessler

Tax Court Concludes IRS Failed to Satisfy § 6751

USA - November 19 2020 In McCarthy v. Commissioner, the Tax Court concluded that the taxpayer’s 2015 tax return incorrectly included two real-estate properties not entitled…

Richard A. Nessler

Sixth Circuit Rejects Taxpayer’s Judicial Estoppel Claim

USA - November 19 2020 On June 20, 2020, the Sixth Circuit in Audio Technica U.S., Inc. v. United States reversed a decision by the District Court for the Northern District…

Richard A. Nessler