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Jurisdiction Income Taxes Tax Court

Eversheds Sutherland (US) LLP

Georgia’s 2024 legislative session: Sine Die tax legislation overview

The Georgia General Assembly passed several significant tax bills during the 2024 legislative session. Among them was the creation of a tax court in the judicial branch, a reduction of the individual and corporate income tax...more

Freeman Law

Tax Court in Brief | XC Foundation v. Comm’r | Tax Court Jurisdiction and Corporate Capacity to Seek Relief

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Summary: XC Foundation (“XC”) was incorporated in California in 2007. In 2008, the IRS issued XC a determination letter recognizing it as exempt from federal income tax under section 501(c)(3) and as a private foundation...more

Freeman Law

Tax Court in Brief | Schwartz v. Comm’r | Collection Due Process; Credit Election Overpayment; Quintessential Tax Procedure

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Schwartz v. Comm’r, T.C. Memo. 2022-125| December 21, 2022 | Vasquez, J. | Dkt. No. 17291-14L - Short Summary:  Eric Schwartz (“Schwartz”) and his spouse divorced.  Pursuant to those divorce proceedings, the state court...more

Freeman Law

A Win for Taxpayers—Section 6330(d)(1) is a Nonjurisdictional Deadline

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Collection Due Process Hearings and Jurisdiction Collection Due Process (“CDP”) hearings are crucial to taxpayers. Taxpayers have a right to a Collection Due Process hearing with the IRS Independent Office of Appeals before...more

Freeman Law

Tax Court in Brief | Cosio v. Commissioner | Collection Due Process and Abuse of Discretion

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Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Rau v. Comm’r, T.C. Opin. 2022-4 | March 7, 2022 | Guy, J. | Dkt. No....more

Freeman Law

The Tax Court in Brief - December 2021 #4

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Ahmed v. Comm’r, T.C. Memo. 2021-142 |December 28, 2021 | Thornton, J. | Dkt. No. 12876-18L - Short Summary. The IRS filed a notice of federal tax lien against Mr. Ahmed with respect to his 2013, 2014, 2015, and 2016...more

Freeman Law

The Tax Court in Brief - December 2021

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Tax Litigation: The Week of December 6 – December 10, 2021 - Coggin v. Comm’r, 157 T.C. No. 12 | December 8, 2021 | Weiler, J. | Dkt. No. 21580-19 - Short Summary: Alice J. Coggin (“Coggin”), who was married during...more

Freeman Law

The Tax Court in Brief - August 2021 #5

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Tax Litigation: The Week of August 23 – August 27, 2021 - Tax Court Case: Estate of Charles P. Morgan, Deceased, Roxanna L. Morgan, Personal Representative and Roxanna L. Morgan v. Comm’r, T.C. Memo 2021-104 | August 23,...more

Freeman Law

The Tax Court in Brief - July 2021

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of July 5 – July 9, 2021 - Peterfreund v. Commissioner,...more

Freeman Law

The Tax Court in Brief

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Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of October 31 – November 6, 2020 - Glade Creek Partners,...more

McDermott Will & Emery

Second Circuit Weighs in on Tax Court’s Refund Jurisdiction

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Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s...more

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