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Searching Content indexed under Trials & Appeals & Compensation by Andrew Roberson ordered by Published Date Descending.
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Supreme Court Grants Certiorari In Case Involving Auer Deference
The US Supreme Court (Supreme Court) granted certiorari in the case of Gloucester County Sch. Bd, which involves a dispute as to whether an unpublished letter by a Department of Education official...
United States
9 Nov 2016
2
APA Challenge To Notice Of Deficiency: QinetiQ Oral Arguments
On October 26, 2016, the US Court of Appeals for the Fourth Circuit heard oral argument in QinetiQ U.S. Holdings, Inc. v. Commissioner, No. 15-2192.
United States
4 Nov 2016
3
Former Tax Court Judge Pleads Guilty To Tax Crimes
Following up on our prior coverage, former US Tax Court Judge Diane L. Kroupa pleaded guilty on Friday to multiple tax criminal charges related to her tax returns and interactions with the Internal Revenue Service.
United States
25 Oct 2016
4
Types Of Tax Court Opinions And Their Precedential Effect
Most tax cases are decided by the US Tax Court (Tax Court). The Tax Court issues two categories of opinions: (1) formally published dispositions; and (2) unpublished dispositions.
United States
19 Oct 2016
5
3M Company, IRS File Reply Briefs In "Blocked Income" Case; Tax Court Orders Oral Argument
3M returns to its argument that Treas. Reg. § 1.482-1(h)(2) is "procedurally invalid" because Treasury and the IRS failed to satisfy the requirements of section 553 of the APA when they promulgated the regulations.
United States
8 Sep 2016
6
Taxpayer Argues First Circuit Should Not Follow Tax Court Decision By Judge Indicted For Tax Fraud
We will continue to follow these matters and provide updates in the future.
United States
24 Aug 2016
7
Tax Court Order Indicates That E-Discovery And Predictive Coding Are Here To Stay
The IRS and the taxpayers had agreed that the taxpayers would run a search for terms determined by the IRS on the potentially relevant documents.
United States
19 Jul 2016
8
Expert "Hot Tubbing" In The Tax Court
The use of expert witnesses in litigation can be tricky. Taxpayers want to avoid the perception that their expert is a "hired gun" who is merely their biased advocate.
United States
18 Jul 2016
9
Tax Court Clarifies The Rules And Grants IRS's Motion To Compel Nonconsensual Depositions
The Tax Court recognized its longstanding position that nonconsensual depositions are an extraordinary method of discovery.
United States
14 Jul 2016
10
Tax Court (Again) Rejects IRS Use Of Secret Subpoenas
On July 8, 2016, Judge Mark V. Holmes of the US Tax Court issued an order in Ernest S. Ryder & Associates, Inc., APLC, et al., v. Commissioner.
United States
12 Jul 2016
11
Tax Court Adopts Rules For Judicial Conduct And Judicial Disability Complaints
In a June 14, 2016 press release (available here), Chief Judge L. Paige Marvel of the United States Tax Court announced the adoption of rules for judicial conduct and judicial disability complaints.
United States
16 Jun 2016
12
"Snow Day" Case Highlights Importance Of Timely Filing Requirements
On June 2, 2016, the US Tax Court issued a unanimous court-reviewed opinion in Guralnik v. Commissioner, 146 T.C. No. 15, addressing several points related to the timely filing of court documents.
United States
8 Jun 2016
13
Fifth Circuit Rejects Substantial Authority Defense To Penalties
Prudent taxpayers analyze the relevant tax law while structuring and implementing transactions.
United States
1 Jun 2016
14
Federal Circuit Narrowly Interprets Limitations Period For Foreign Tax Credit Refund Claims
The Federal Circuit is the first appellate court to address this issue, and taxpayers paying foreign taxes need to be aware of the ramifications of the decision.
United States
15 Sep 2015
15
Statute Of Limitation: Congress Overrules Home Concrete And Retroactively Removes Some Taxpayer Defenses
On July 31, 2015, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236; Pub. Law No. 114-41) (the 2015 Act) into law.
United States
20 Aug 2015
16
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
17
Tax Court Holds That Inadequate Privilege Log Subjects Putatively Privileged Documents To Disclosure
The IRS has broad authority to request information from taxpayers during an examination or in discovery in a docketed tax case.
United States
2 Jun 2015
18
Court Weighs In On Deadline For Filing FTC Refund Claims
The U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds.
United States
15 Oct 2014
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