Jones Day Presents: LB&I Examination Strategies: Process Overview
Podcast: Cum-Ex Dividend Trade Investigations
Supreme Court’s Rulings On Same-Sex Marriage Spark Many Questions On Employee Benefits
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
The Internal Revenue Service (IRS) issued a news release reminding taxpayers to submit their 2019 income tax returns by July 17, 2023, to claim their refunds. Internal Revenue Code Section 6511 provides the period in which a...more
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
When is a protective refund claim available? Taxpayers often face uncertain outcomes in litigation or business transactions, giving rise to contingent tax refund claims. For example, if a pending lawsuit ends in a favorable...more
The executor of the Estate of Tamir Sapir is seeking a refund of more than $25 million of fiduciary income tax alleged to have been overpaid to the Internal Revenue Service (“IRS”). While the refund suit is currently teed up...more
Once a taxpayer overpays a tax, it is necessary to file a claim for refund before any action can be undertaken to seek a refund of such tax from the government. The purpose of the claim for refund is to place the IRS on...more
The California Franchise Tax Board (FTB) has announced plans to make adjustments to interest rate calculations in certain circumstances involving May Department Stores v. United States to approximately 27,000 taxpayer...more