Recent tax court cases. Here are tax cases Inland Revenue has taken .

Recent tax court cases 11. Legalbitstream offers free searchable databases of Federal tax law, including Tax Cases and IRS Materials. Jan 22, 2024 · Explore recent Supreme Court rulings (2023) on income tax issues. When you enter a Docket Number that matches a case in the system, that case will display. Supreme Court concluded its 2020-2021 term, with two final decisions announced on July 1, 2021. A recent Tax Court case, Cardulla v. Royal visitors aside, the decision of the Federal Court in Oracle Corporation Australia Pty Ltd v Commissioner of Taxation (Stay Apr 2, 2024 · While many cases have been resolved in favor of the government, this is another in a line of more recent cases where Tax Court judges expressed skepticism about the IRS’s approach. They determined the activity reported on the Schedule F was rodeoing, not ranching. This tax was repealed in 1871, and the Supreme Court struck down a flat rate federal income tax in the 1890s for failing to account for the population of each state. The US Supreme Court will hear a case this fall that could transform the way the federal government taxes unrealized gains, and will also consider picking up three more large tax cases for the term that opens next week. Many people use trusts and gifts as estate May 20, 2024 · In light of CCA 202352018, where the IRS took the position that the consent of beneficiaries to a trust modification allowing for income tax reimbursements to a grantor was a gift by the beneficiaries, it is interesting that they apparently did not try to argue something similar as a fallback argument in the Anenberg case. This article discusses the potential impact of two recent U. Raimondo (Docket No. Coming on the heels of the Fisher Second, the court determined that the proceeds didn't qualify for an exclusion for a return of capital. Ground Judgment >> Judicial Review. Dec 22, 2021 · This High Court decision concerning the obligations of a purchaser to notify claims made under warranties, tax warranties and a tax deed illustrates the difficulties of providing valid notification of potential claims where investigations arise but the results of that investigation are uncertain. Memo. For example, two years ago, in Kennedy v. A recent Tax Court opinion demonstrates the complexities involved when a taxpayer attempts to discharge tax liabilities through bankruptcy proceedings. Per Tax Court Rule R. Commissioner, and Mill Road 36 Henry, LLC v. For the benefit of our readers, we have briefed the case below: Complex Media, Inc. " When a court hears a case “de novo,” it will decide the issues on Oct 24, 2023 · The federal income tax treatment of interest deductions is often complex and unintuitive. Visit our tax blog for in-depth analyses, unique insight and superlative perspective on tax matters: A recent Tax Court decision addresses the “reasonable cause” standard — a frequent issue in the IRS-penalty context. Aug 22, 2024 · In three recent cases, the Tax Court analyzed sections 2036 and 2038 and their potential application to split-dollar life insurance agreements. Comm’r, T. ” Jul 19, 2023 · In the second case, Supreme Court decided that the Danish company (also unnamed) was obliged to pay withholding tax of DKK817 million ($123 million) on interest paid to Luxembourg holding companies between 2006 and 2008. 4 This penalty Dec 29, 2022 · The Supreme Court observed that since the judgment of this Court was dated 16. Oct 28, 2024 · In recent months, key tax court cases have clarified the application of R&D tax credits and the associated expenses and were upheld at the Appellate Court level. In the Reesink case, Mr. Decisions pre-May 2022 can be […] Jul 1, 2024 · Fourteen sections of the Internal Revenue Code are central to the taxation of Subchapter S corporations and their shareholders. COT v British United Shoe Machinery SA (Pty) Ltd, (1964, (3) SA 193, (FC), 26 SATC 163 The taxpayer can ask the tax court to consider whether the IRS should be able to take certain collection actions and, in some cases, the taxpayer may also contest the underlying tax liability (the tax court has to have subject matter jurisdiction over the tax or penalty before it can be challenged in a CDP hearing in the tax court). This comprehensive and timely updated tax research resouce contains tax cases from the Supreme Court, Circuit and District Courts, US Tax Court, and more. ” Sep 20, 2023 · The case of Jefferies Group and Subsidiaries, DTA Nos. District Judge Vernon S. Dec 4, 2024 · Through the years, the US Tax Court has provided significant clarification on the gift tax consequences of terminating qualified terminable interest property (QTIP) trusts. U. A very recent IRS tax court case victory (denying trader tax status and MTM) has caused a stir in the media and among traders. Jan 11, 2023 · A recent Tax Court case: Luu v. Residence and Source Tax Court Cases. Commissioner (T. irs. 829218 and 829219 (Aug. , the court's presidentially appointed judges travel across the country to conduct trials. The TC Case No 11641 : Additional tax is a penalty of an administrative nature which cannot be equated with a fine imposed by a criminal court: sections 75(1)(a) and 76(1)(a) of the Income Tax Act, 1962 (11641) [2006] ZATC 6; 70 SATC 68 (4 December 2006) May 2006 Jan 9, 2025 · Taxpayers had mixed success in two recent research credit cases in the United States Tax Court. South Africa: Tax Court Database last updated: 17 March 2025 Most recent decision: 6 February 2025 Number of decisions: 249 Jan 24, 2021 · With the facts considered in the case, the court held the parties’ agreement controls the determination of whether the taxpayer performing research has retained substantial rights. 13368-15 and 19898-17 Jan 31, 2025 · Zuch accepted by US Supreme Court involves important questions about the due process rights of taxpayers. Here are tax cases Inland Revenue has taken Accordingly, taxpayers with rental activities and losses are wise to consult tax advisors regarding whether they may deduct their losses under Section 469. The IRS determined the results of all research Enercon performed in the course of fulfilling this contract were retained by Vericor due to the unequivocal nature Commissioner, United States Tax Court, T. In Little Sandy Coal v. Getting A Higher Percentage – Let’s Start At The Very Mar 22, 2023 · 2022; Date of Delivery: Case Number: Applicable Legislation: Keywords: 29 December 2022: IT 45997: Tax Administration Act, 2011. In addition to the above cases, other recent Tax Court cases include Plateau Holdings, LLC v. Commissioner, TOT Property Holdings, LLC v. Under current tax law, damages taxpayers receive for personal physical injury or physical sickness are excluded from gross income. II. Tax Court? Oct 24, 2022 · In its opinion, the Tax Court acknowledged the substance of the distribution (recognizing that an intangible asset can be part of a distribution), but the Tax Court found the partnership failed to restate all partner capital accounts immediately prior to the distribution, as required by the partnership agreement and the section 704(b) regulations. 13 (Nov. Paletta’s straddle transactions were acceptable from a tax perspective. He is an author and public speaker on tax, business and economic matters. This type Dec 2, 2022 · Musselwhite, T. In 1861, Congress and President Abraham Lincoln imposed a 3 percent tax on annual incomes over $800 to finance the Union war effort. Nov 11, 2022 · The United States Tax Court held IRS Notice 2017-10 is invalid in a November 9, 2022 decision in Green Valley Investors, LLC, et al. Commissioner , 161 T. Sep 9, 2024 · Summary: Recent High Court rulings offer crucial insights into income tax issues. section 165 has historically allowed taxpayers to deduct three types of losses: those incurred in a trade or business, those incurred in a transaction entered into for profit, or losses arising from other causes, such as theft. Our courts have consistently maintained that the source of employment income is located at the place where the services are rendered. To browse, scroll to the bottom of the search screen. Tax administration: Rule 31 statement be struck out on the basis that it introduces an impermissible new ground of assessment in the appeal. A pro-taxpayer ruling would uphold the Tax Court’s jurisdiction over underlying liability disputes. Supreme Court in 2024 issued two significant opinions that, despite neither being from a tax case, will have broad consequences for taxpayers seeking to challenge tax regulations and other issued guidance. Memo 2023-24 (Feb. The recent Tax Court case Sherman, T. 2022-57, is not the first Tax Court case in which the taxpayer argued with the IRS over whether the real estate was an investment versus held in the ordinary course of a trade or business. 10. Sep 3, 2024 · The IRS is taking this issue very seriously. 268A : Appeal-Instructions-Circulars-Monetary limits-Revision-Penalty- Concealment penalty-Monetary limit is also applicable to proceedings under section 263 of the Act-The CIT u/s. A v Commissioner For The South African Revenue Services (46206) [2023] ZATC 1; 84 SATC 225 (21 February 2023) Dec 5, 2023 · Supreme Court hears a case that could wreak havoc on the tax code A couple who owned a controlling interest in a foreign corporation argue that a controversial Trump-era tax is unconstitutional Nov 6, 2024 · Loper Bright Enterprises v. Jan 7, 2022 · Cases include tax evasion, Ponzi schemes, COVID fraud, cyber crimes. United States Tax Court. In the IMG (UK) Ltd. Mark D. For the last few weeks, the Tax Court Tennessee woman pleads guilty to COVID-19 employment tax credit scheme; Broward tax preparer arrested and charged with tax fraud; Long Island tax preparer indicted for tax and Covid loan fraud schemes resulting in losses of $12 million; March 11, 2025. 31. Reinforced by cases like the U. I. Tax treatment of raising fees: Whether the raising of fees are deductible “interest or similar finance charges” as envisaged in section 24J of the Income Tax Act 58 of 1962 In this Insight, Freeman Law takes a closer look at the top 10 Tax Court cases of 2020. Reesink and a relative sold a San Francisco apartment building for $1,400,000. 2021-14 | February 10, 2021 | Halpern, J. Mar 27, 2013 · The recent Tax Court cases of Reesink v. Nos. , No. Merely paying or incurring an expense is not sufficient to entitle a taxpayer to a deduction under Sec. Commissioner. The Court was also highly critical of the conduct of counsel for the Respondent. United States Tax Court cases search (case, order, opinion, practitioner) citation and style manual; transcripts & copies; tax court reports: pamphlets Aug 8, 2006 · The Tax Court resolves disputes between taxpayers and the Internal Revenue Service (IRS). 2023), examined whether a Connecticut estate could claim a charitable deduction under Internal Revenue Code Sep 3, 2008 · Plus, the cases were argued poorly in court; often by the traders without a trader tax expert’s help, or by an expert who was not sufficiently strong enough on trader tax law. The five-member bench Federal Court led by the Chief Justice had reversed the Court of Appeal’s decision and handed down a unanimous ruling that Section 4C of the Income TaxAct 1967 is unconstitutionalas it contravenes Article13(2) of the Federal Constitution Jan 15, 2025 · “The outcome of this case is important because taxpayers should not be in a position where they lose their ability to assert their procedural rights—and, as was the case in Zuch, the ability to challenge the underlying tax liability—in Tax Court solely because the IRS has eliminated the tax liability through unilateral action,” said Ted Tax-related court cases Tax Fraud Blotter: Dirty laundry Startup shut down; healthy, wealthy and crooked; won't ever stand the strain; and other highlights of recent tax cases. is article explains the rules related to conservation easement donations, long-standing support by Congress for corresponding tax enticements, and 20 recent enforcement actions by the IRS designed to halt what it considers abusive taxpayer behavior. Commissioner, 122 T. Date: December 11, 2023. Need assistance litigating in the U. United States, a case that could affect broad swaths of the U. after more than six year income tax issued notice assuming difference amount as income from other source and ordered to pay income tax with interest and penalty. IRS. 400 Second A recent Tax Court case illustrates the reach of the economic substance doctrine and the step transaction doctrine. The Rajasthan High Court stated that the Jurisdictional Assessing Officer (JAO) lacks jurisdiction to issue income tax reassessment notices under section 148 of the Income Tax Act, 1961. As the case demonstrates, whether a taxpayer acted with reasonable cause and in good faith is determined on a case-by-case basis. A petition in another federal tax case deals with the timing for filing partnership petitions with the IRS. Overview of Conservation Easement Donations and Tax Deductions Oct 23, 2024 · Background. As a reminder, Freeman Law publishes a clear and concise summary of all Tax Court decisions released for any given week in its weekly edition of “The Tax Court in Brief,” which can be found on our Insights webpage. You may, but do not have to, include the letter suffix (S, L, SL, R, X, D, or P) of the Docket Number to find a case. Tax Court cases, see our weekly post, The Tax Court in Brief. Income Tax or Real Property Gains Tax Jan 2, 2024 · This year, the US Supreme Court will weigh several prominent cases affecting tax administration, including a challenge to a foreign earnings provision estimated to generate hundreds of billions of dollars, and a fishing business’ challenge to a decades-old doctrine that gives deference to regulatory agencies when interpreting ambiguous statutes. However, in a new case, Sinopoli, TC Memo 2023-105, 8/14/23, the shareholders of Bombay High Court: S. Raimondo, 144 S. Tax Court recently ruled in favor of the IRS in a major transfer pricing case involving 3M (3M Co. But if the Supreme Court tries to send the IRS a message—and the agency chooses to listen—a much broader group of taxpayers could benefit. Seeking grant of regular bail - availing ineligible Input Tax Credit (ITC) on the basis of fake invoices received from non-operational firms - HELD THAT:- This Court finds that the entire case of the prosecution is founded upon the documentary material and as far as the alleged ineligible availment of Input Tax Credit of Rs. g. suffered a tax loss of $53,639 for Harmons’ personal returns and $266,366 for his clients, for a total tax loss of $320,005. Please join us for a live Webinar on March 17, 2021, at 1:00 pm EST. Mar 19, 2025 · BPR claim fails: Estate of G Tanner v HMRC [2025] UKFTT 328 (TC) (12 March) is another in what is becoming a long line of cases about the availability of business property relief (BPR) for a holiday accommodation business. While generally donors who donate appreciated property to a public charity do not recognize capital gain — resulting in significant tax savings — the case explores an important exception. The tax court disagreed with the IRS. Commissioner of Internal Feb 1, 2024 · Under the so-called “Augusta rule,” homeowners can avoid any tax consequences for certain short-term rentals. Dec 28, 2024 · In this case, a bench comprising Justices BR Gavai and KV Viswanathan quashed a criminal case registered against HDFC Bank Ltd. Commissioner, T. The decision is an indictment of the CRA’s tactics during the litigation and, in particular, an indictment and condemnation of the CRA’s ongoing flouting of court orders. Mar 26, 2024 · Tax Court declines to limit discovery in R&D credits case March 26, 2024 The Tax Court has denied a taxpayer’s request in Kapur et al. Apr 26, 2022 · Commissioner, 110 T. S. Here are the details. Commissioner,[1] the taxpayer was an architectural firm. In the recent case of KEN CC v CSARS, VAT2218 (VAT) [2023] ZATC CPT, the Tax Court (Cape Town) was tasked with deciding the dispute that had arisen between KEN CC (the vendor) and SARS concerning the vendors supply of services to foreign tour operators (FTOs) incorporated outside of South Africa. Jun 2, 2021 · As noted above, the Supreme Court has confirmed that the APA applies to tax guidance. This case is significant since it adds to the conservative Supreme Court's recent string of decisions expanding religious freedoms. While taxpayers are generally entitled to deduct ordinary and necessary expenses necessary to conduct a trade or business or for the production of income, Section 183 of the Internal Revenue Code limits the ability to claim deductions arising from an activity that is not engaged in “for profit IR has more than 90 cases before the courts as of the end of June and sentences have been handed down over recent months for tax evasion and other offences. 30, 2023) (Judge Buch), the deadline for the taxpayer to file his Petition fell on Thanksgiving Day. 2244 (2024), and Corner Post v. Search for a specific court case or term to read tax court documents on Tax Notes. 31, 2023), involves refund claims of over $10 million. concerned was an N. even though purchase was made from the overseas income. Commissioner Of Internal Revenue, T. Jul 19, 2023 · [2] The matter before the court is an appeal in terms of s 107 of the Tax Administration Act 28 of 2011 by the taxpayer against the decisions by the Commissioner for the South African Revenue Service (i) to disallow as a deduction in terms of s 11(a) (read with s 23(g)) of the Income Tax Act 58 of 1962 the amount of R15 320 263 that was Dec 1, 2023 · In total, the U. 440, 441 (1998) (applying the term "newly discovered evidence" in the context of a motion to reconsider pursuant to Rule 161, Tax Court Rules of Practice and Procedure); Fairmont Aluminum Co. You can search for tribunal judgments and decisions on cases heard by the First-tier Tribunal (Tax Chamber) and Upper Tribunal (Tax and Chancery Chamber). Alaska Chiropractic Society, et al v. v. 2023-63, highlights the fact that taxpayers bear the burden of substantiating not only the amount of the deduction but also that the purpose underlying the deduction is ordinary and necessary to operating Jan 26, 2024 · Recent income tax judgments. There are many Supreme Court cases related to income tax issues that were decided during 2021 Dec 1, 2022 · Musselwhite, T. This is also the predominant principle applied internationally. 162(a). Jul 30, 2021 · On June 30, 2021, the U. Cook, CPA, CGMA. That was the lesson learned by Scott Hoensheid in a recent Tax Court case that resulted in a lost charitable deduction and capital gains tax. tax code. Three recent court cases touch on issues that often face clients. M. These cases include the agency's most prominent and high-profile Jun 15, 2021 · In so holding, the court drew on several earlier cases and provided precedent for many more after — the case is cited in 35 subsequent federal cases and four IRS revenue rulings, according to Thomson Reuters’s Citator 2nd Series. tax issues before the Tax Court, and taxpayer-favorable issues absent from recent IRS guidance about the Tax Court disputes. You can filter with dates, party’s name and judge’s name. Court of Appeals for the Fifth Circuit's Chamber of Commerce v. Dec 16, 2024 · Why this tax case matters. In reaching its decision, the Tax Court emphasized that tax affecting was only appropriate in this case “given the unique setting at hand. Commissioner [1] (Little Sandy Coal), the Court determined that the taxpayer did not provide the proper documentation to support its experimentation process necessary for purposes of claiming the R&D tax credit. 2020-71, 119 T. 3 If taxpayers file late, inac-curate, or substantially incomplete Forms 5471, then the IRS may assert a penalty of $10,000. was a publicly traded Delaware corporation and the parent of Sep 20, 2023 · The case of Jefferies Group and Subsidiaries, DTA Nos. This case centered on the “ contingent on success ” requirement of the funded research exclusion as part of IRC Section 41. Commissioner, addressed a number of issues that may be relevant for Two recent court cases highlight how taxpayers can lose their R&D tax credit claims. These lessons are Dec 12, 2022 · The tax administration adjusted the losses reported by ST Dupont for corporation tax in France over the 2009, 2010 and 2011 financial years. WASHINGTON — Internal Revenue Service Criminal Investigation (IRS-CI) began counting down the top 10 cases for calendar year 2021 on its Twitter account on January 3. In three recent cases, the Tax Court analyzed Mar 6, 2024 · Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Date of Delivery: Case Number: Applicable Legislation: Keywords: 13 January 2025 New! IT 76795: Tax Administration Act, 2011. Contact: newsroom@ci. 2022-126 (2022) provides some useful guidance and builds on what I’ve found in practice. ~ Latest Tax & GST Headnotes - part of the Australian Tax Reports online service. Department of Labor (validity of temporary Section 7874/inversion regulations) and the U. 4759-22 (T. Background. (See "To Tax or Not to Tax" at the bottom of the page. As a result, the IRS determined that all deductions on the Schedule F should be disallowed. Aug 8, 2024 · 02/02/2022 - Since December 28, 2020, over 750 new features have been added to DAWSON, the Tax Court’s case-management system. Tax Court Litigation Attorneys. Mar 1, 2024 · This semiannual update surveys recent federal tax developments involving individuals. Background Dover Corp. United States PDF: Decision regarding the excise tax on wagering for games conducted by permittees, not operators. 3). Much of the amount in controversy was attributable to New York Jul 30, 2024 · This is a list of litigation decisions where HM Revenue and Customs (HMRC) considered tax avoidance was involved and a decision was received during 2023 to 2024. 1377, 1383-84 (1954) (same, regarding a motion for new trial pursuant to Rule 162, Tax Court Rules of Dec 5, 2023 · The Supreme Court on Tuesday is hearing oral arguments for Moore v. 28, 2023)] Observation: Although the outcome in Cecil (if followed in other cases) should be welcome news to taxpayers, questions still remain. gov. the four cases in which the Tax Court most recently issued rulings involve tax years 2010 – 2013, and there are cases docketed with the Tax May 3, 2024 · The Circuit Court noted that it reviewed the Tax Court’s legal rulings de novo—that’s Latin for “from the beginning. Further, Denham argues that the Tax Court is not bound to the same conclusion reached in Soroban, echoing a procedural rule that was recently employed by the Supreme Court in Loper Bright Enterprises Inc. 18 crores is . Nov 1, 2023 · Editor: Mark G. (RIA) 2023-030 (T. 3 days ago · State Tax Cases Docketed Lists State Tax Cases Docketed State Tax Cases Docketed PDF - March 27, 2025; State Tax Cases Docketed XLSX - March 27, 2025 Mar 19, 2025 · Court: Fifth Circuit › Texas › U. The Tax Court denied the Dec 11, 2023 · Cases include tax, cryptocurrency and COVID fraud schemes. Feb 24, 2025 · 2025. ” Another case involves the issue of unforeseen circumstances as an exception to the two-year ownership and usage requirement for the principal residence gain exclusion Nov 13, 2024 · Australia has had an interesting few weeks in regard to royalty. Commissioner marks another shift in the landscape of conservation easements with significant implications for taxpayers whose conservation easement deductions were denied in the past, and for those considering claiming them in the future. Commissioner and Dennis Lincoln and Julia Lincoln v. This article focuses on a recent Tax Court case involving the proper characterization of purported intercompany loans between two S corporations. Jun 14, 2022 · The FCA concluded that those were critical issues because “no minimally competent tax lawyer could have sanctioned Mr. Items released week ended 21 March 2025 McPartland v Commissioner of Taxation [2025] FCAFC 23 – taxpayer has burden to prove what the assessment should have been INterNatIONaL taX JOUrNaL September–OctOber 2021 RECEnT TAx CouRT CASE REvEALS RARE uSE of foRM 5471 PEnALTy DEfEnSES 54 Taxpayers file Forms 5471 as an attachment to their federal income tax returns. CIT case, services provided to BCCI were classified as Fee for Technical Services (FTS) under the India-UK DTAA, making the income taxable in India. In response, the French manufacturer appealed the tax authority’s decision to the Paris Administrative Court, which set aside parts of the tax assessment, including on royalty payments. Paletta’s plan to portray his trades as a business”. Aug 21, 2018 · A recent Tax Court precedential decision raises a really interesting question about the application of §7451’s tolling provision to seemingly late-filed Tax Court Petitions. _____ Taiwo Oyedele is the Head of Tax and Regulatory Services at PwC Nigeria and Tax Leader for PwC West Africa. CIR TC Memo. Broderick, is 1:24-cv-09918, Goldeneye Advisors, LLC v. Apr 10, 2023 · A recent Tax Court case provides important guidance for donors and charities making and negotiating gifts of appreciated property. Two new cases in 2024 Mar 18, 2025 · These cases can be searched (but only as a free text search in the full text of the case), or browsed by eg: year, court etc. Raimondo, where the Supreme Court referenced earlier case law in concluding that stare decisis is not an “inexorable command. Commissioner of IRS PDF: Decision regarding individual's claim of exemption from federal income tax liability. However, two things stand out about this case — the first is that it was an ordinary loss recast into a capital loss. HMTK, 2022 TCC 112. C. This decision affects 90,000 notices of reassessment issued during the pandemic when both old and new laws overlapped, causing widespread disputes and legal actions. Order 53 of the Rules of Court 2012 Section 4(a) Income Tax Act 1967 (ITA 1967) Real Property Gains Tax Act 1976 (RPGTA 1976) Sumur Marketing Sdn Bhd & Sumurwang Industries Sdn Bhd V Ketua Pengarah Hasil Dalam Negeri. IR-2022-04, January 7, 2022. Memo 2023-84), holding that the taxpayers could not claim a research credit under Section 41 based on a lack of technical uncertainty and because certain projects constituted funded research. | Dkt. In both cases this was because the reorganised holding companies were ruled not to be the beneficial owners of the interest. 01/26/2022 - After assessing public health and other factors relating to nationwide COVID-19 cases, the U. For more coverage of U. 2024–28) to limit discovery to the two largest projects from a statistical sampling frame used to support a research credit claim. Supreme Court on June 28, 2024. CIR v Black 1957 (3) SA 536 (A), 21 SATC 226. George vs. It summarizes notable cases, rulings, and guidance on a variety of topics issued during the six months ending October 2023. 263 of the Income-tax Act directed the AO to initiate a penalty for concealment, which was not originally initiated in the assessment order-Tribunal set aside the order of the Commissioner-On You can search for tribunal judgments and decisions on cases heard by the First-tier Tribunal (Tax Chamber) on the Find Case Law website (external link) which includes decisions from May 2022 and some older decisions (between April 2019 – April 2022). till 2019and Jan 24, 2024 · During the audit and before the tax court, the IRS argued that the Schedule F activity was not a business activity. Nov 1, 2024 · An intercompany loan between related corporations may be recharacterized as an equity contribution by the companies’ shareholders, resulting in a constructive dividend to the shareholders. Mr. Some decisions may be subject to May 23, 2023 · Central Goods and Services Tax, 2017; Section 130 - Observing that it was "premature" on the part of the High Court to quash a show-cause notice issued under Section 130 of the Central Goods and Mar 22, 2023 · A recent Tax Court case, Estate of Block v. Tax Court has determined that it is not appropriate to conduct in-person proceedings through February 25, 2022. During this term, some important tax decisions were handed down. Commissioner, 22 T. Tax cases receive more media attention each year reflecting public concern about appropriate action being taken when taxpayers break the law. Whether the expenses are deductible often hinges on whether they are properly substantiated, under the general requirements for substantiation or, where applicable, the heightened substantiation requirements of Sec. The King, 2022 TCC 169, is a recent decision of the Tax Court of Canada that addresses “alternative assessment techniques”. Commissioner and Adams v. Start now on the Find case law website. Here's what happened. 1 Over the 12-month period ending March 2024 covered by this article, several of these sections and others affecting S corporations have been addressed by recent legislation, court cases, and IRS guidance. In Smith v. It’s Holsinger vs. This is in spite of the fact that the Tax Court itself concluded that Mr. (CCH) 1502 (June 1, 2020), the court recognized that where a family loan is involved, an actual expectation of repayment and an intent to enforce the debt are crucial for a transaction to be considered a loan. Feb 24, 2023 · The U. No. Through this write-up, let us analyze key income tax judgments from the income tax appellate tribunal, the high court, and the Supreme Court. , Bobby Branch, Tax Matters Partner v. It provides users with access to headnotes for recent tax and GST decisions by the Jul 19, 2021 · Recent Tax Court Cases on Common Issues. But Zuch could also have a rippling impact on US Tax Court jurisdiction and on those who practice before the Tax Court. Commissioner, 160 T. 274(d New Tax Court case on source Why this matters? A recent tax court judgment substantially deviates from the principle emanating from case law to-date. Jan 19, 2024 · Justice Department had to be nudged by the Court in his client's criminal case to even nab Glen, and then he got treated like the only client he had during 50 years of tax cheating was the one Jan 13, 2022 · The Tax Court’s decision focuses on section 183, the so-called “hobby loss” provision. In each case, the taxpayers attempted to limit discovery to a small number of To search for a case by Docket Number, you must include the dash in the Docket Number (e. 19 (2004), addresses an aggressive, but ultimately successful (pending appeal), effort by a taxpayer to obtain a tax ben-efit through a deemed liquidation under these rules. Oct 23, 2024 · Recent Supreme Court Decisions May Affect Tax Practice The case, assigned to U. ” Dec 6, 2024 · A recent Tax Court case, Dover Corp. Meyer, Borgman & Johnson, Inc. Cases Commenced in the Courts of Appeals, December 2024 No documents can be filed with the Court at this email address. Based in Washington, D. 8:9, the Appellate Division opinion (A-1144-22, decided April 17, 2024) is published in the Tax Court Reports and is binding only on the parties in the case and its use in other cases is limited. The Cameco case in Canada can be viewed as one of the recent prominent TP cases in the global tax community. District Court for the Northern District of California Type: Federal Tax Suits › Taxes Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. 8/29/23) (order denying petitioner’s motion for a protective order), and Kapur, T. Court of Appeals for the District of Columbia Circuit's Florida of tax enforcement procedures. 2023 South Africa: Tax Court Decisions February 2023. Oct 7, 2022 · A Tax Court judge has slammed the Canada Revenue Agency and the federal Justice Department for "egregious conduct" that threatened to deny three taxpayers the right to a fair trial in an epic Apr 11, 2023 · Timing is everything. These cases include the agency's most prominent and high-profile investigations Nov 22, 2021 · A recent Tax Court Case, Smaldino V. Since 1984, courts were required to give deference to agency interpretations of Dec 1, 2022 · On remand, the Tax Court held that, despite an ambiguous mandate from the Ninth Circuit, it had the power to vacate a prior decision in a case and enter a new decision based on an agreement between the taxpayer and the IRS. purchase rate was 19 lac less than circle rate . See the Press Release . As a result of those cases – Loper Bright Enterprises v. Clayton man pleads guilty to COVID-19 assistance fraud, aggravated identity theft, and Court: Ninth Circuit › California › U. Sep 24, 2020 · On June 26 2020, the Federal Court of Appeal upheld the September 28 2018 Tax Court of Canada decision in the case of Cameco Corporation (Cameco) vs the Canada Revenue Agency (CRA). Jul 18, 2024 · The U. The case emphasizes the need for an attorney knowledgeable in both tax and bankruptcy cases to ensure that the the best, most-viable tax arguments are put forward in the proceedings. R. As I write this missive, we have entered the year 2024, which marks a new beginning for everyone. Four Categories of Workers Readers must grasp the main categories of workers to appreciate this article. WASHINGTON — IRS Criminal Investigation (CI) will count down the agency's top 10 cases for calendar year 2023 on its X and LinkedIn accounts beginning Dec. Tax Court Warning about Tax Scams Decision regarding fuel excise tax. 2021-127, November 10, 2021 has lots of important lessons on how to do an estate plan properly. District Court for the Northern District of Texas Type: Federal Tax Suits › Federal Tax Suits: IRS-Third Party 26 USC 7609 Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. ) Jan 24, 2025 · For Zuch, a Supreme Court ruling in her favor would result in a remand to the Tax Court for consideration of whether she owed the tax and, if she prevails there, a declaratory judgment in her favor. Hanaco Venture Capital, Ltd Feb 3, 2025 · Category: Current Tax Cases. The CRA has until September 25 2020 to seek leave to May 1, 2023 · recent tax court cases The Tax Court is often asked to decide whether taxpayers’ claimed business expense are deductible. 22-451) was issued by the U. Oct 20, 2022 · The Tax Court recently released its decision in Choptiany v. Jul 23, 2023 · can you send 2 cases verdict where government circle rate and purchase rate was different . Mar 18, 2025 · Two recent Tax Court cases, Phoenix Design Group Inc. Ct. We will be discussing these and other relevant cases in detail. Whether the court Mar 11, 2021 · In this case, the Tax Court denied a research credit claim based on the interpretation of the 80% experimentation test in the regulations governing the research tax credit. Jul 21, 2020 · In a recent tax court case, Estate of Bolles v. /its officials for violating notice issued by the Income Tax Jan 22, 2025 · The South African Institute of Chartered Accountants (SAICA) is the foremost accountancy body in South Africa and one of the leading Institutes in the world. , 123-18). One involves the tricky issue of what is a taxpayer’s “tax home. In addition to the 2022 notice that characterized these transactions as listed and imposed penalties for failure to report, other Tax Court rulings similarly A recent Tax Court case dealt with a familiar topic: Theft losses. Plea And Sentencing 6 days ago · Cases as seen the Tax News AU newsletter. A recent Tax Court case dealt with a familiar topic: Theft losses. In Madiodio Sall v. In addition to the 2022 notice that characterized these transactions as listed and imposed penalties for failure to report, other Tax Court rulings similarly Further, Denham argues that the Tax Court is not bound to the same conclusion reached in Soroban, echoing a procedural rule that was recently employed by the Supreme Court in Loper Bright Enterprises Inc. This therefore calls for an urgent review of the tax laws. search (case, order, opinion, practitioner) citation and style manual; transcripts & copies; tax court reports: pamphlets The United States Tax Court announced today that Judge Patrick J. The case is significant due to its broader impact on transfer pricing allocations and uncertain tax positions (UTPs) with respect to countries that impose foreign restrictions on royalties, including China and Brazil. Urda has been elected Chief Judge to serve a two-year term beginning June 1, 2025. Oct 3, 2024 · The Supreme Court has ruled in favor of the tax department, stating that after April 1, 2021, the Income Tax Act must be read with its new provisions. Workers fall into four groups: statutory employees, statutory non-employees, Since the Kiva Dunes decision in 2009, the conservation easement cases have largely gone against taxpayers, and we note that it takes quite some time for a case to make its way to the Tax Court (e. Some decisions may be subject to Apr 2, 2024 · While many cases have been resolved in favor of the government, this is another in a line of more recent cases where Tax Court judges expressed skepticism about the IRS’s approach. 4 days ago · Find federal court documents, tax case orders, opinions, petitions & more. Jul 18, 2023 · The Tax Court recently ruled in favor of the IRS in Mark Betz and Christine Betz v. Board of Apr 5, 2024 · The recent US Tax Court decision in Valley Park Ranch v. 2024-28, involved disputes over denied credits for increasing research activities (research credits). Supreme Court decisions—Loper Bright Enterprises v. I. Commissioner indicate that investment property can include property that is later converted into the owner's residence or that was previously the owner's residence. Dec 13, 2023 · The Supreme Court in Skatteforvaltningen v Solo Capital Partners LLP [2023] UKSC 40 held that a claim for repayment of monies by the Danish tax authorities, alleged to have been fraudulently obtained by the appellants, was not rendered inadmissible by the well-established ‘revenue rule’ that the courts of one country will not enforce the tax laws of another. 2023, and having regard to the Telecom Policy, which commenced from the year 1999, the payment of interest for the period for which the tax demand is now to be met in respect of these cases stands waived. ixwyy rpotedp umh safqo auvf fvyuqfla jrv snqd ahth fnh ymiz gup xwgrs qcqnov outtks