Searching Content indexed under Tax Authorities by Roger Jones ordered by Published Date Descending.
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IRS Rules (Again) That Taxpayers Are Not Entitled To Claimed Refined Coal Credits
This, according to the IRS, was fatal to any claim by the taxpayers to refined coal credits related to the LLC's production of refined coal.
United States
11 Aug 2017
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
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
Supreme Court Issues Opinion Addressing Interplay Between APA Procedural Compliance And Chevron Difference
In Encino Motorcars, LLC v. Navarro, Sup. Ct. No. 15-415 (June 20, 2016), the Supreme Court of the United States invalidated a regulation issued by the US Department of Labor under the Fair Labor Standards Act.
United States
6 Jul 2016
Commissioner Files Opening Brief In Ninth Circuit Appeal Of Altera
The Commissioner's arguments on brief are very specific to the context of Reg. §§ 1.482-1(b)(1) and 1.482-7.
United States
6 Jul 2016
IRS Issues New Procedures To IRS Appeals For Requesting Assistance From Exam In Docketed Tax Court Case
Under the new procedures, Appeals will send a request for Exam's assistance if Appeals determines that the new information merits additional analysis or investigation.
United States
4 Jul 2016
Altera: How To Challenge Tax Regulations On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under section 482 requiring participants in qualified cost-sharing agreements (CSAs) to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
5 Oct 2015
The New Section 6501(c)(10) Regulations
Under § 6501(a), the IRS generally has three years from the date a tax return is filed to assess additional tax.
United States
24 Apr 2015
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
Ensuring Timely Filing With Private Delivery Services
Most of us are aware of the timely-mailed-timely-filed "mailbox rule" contained within the Internal Revenue Code.
United States
4 Jun 2014
Challenging Regulations After Mayo And Home Concrete
In the wake of the Supreme Court of the United States’ recent tax opinions in Mayo Foundation for Medical Education & Research v. United States, 131 S.Ct. 1836 (2011), and United States v. Home Concrete & Supply, LLC, 132 S.Ct. 1836 (2012) taxpayers have additional arguments at their disposal to challenge U.S. Department of the Treasury regulations.
United States
6 Dec 2013
The 3M Case: Can The IRS Overrule The Supreme Court?
In March 2013, 3M filed a petition with the U.S. Tax Court challenging the Internal Revenue Service's determination that $23.6 million in additional royalty income should be allocated to 3M's U.S. headquarters from its Brazilian subsidiary.
United States
27 Sep 2013
CCRC Fees - A Primer On The Tax Treatment Of Entrance And Monthly Fees
Continuing care retirement communities (CCRCs) are professionally managed retirement communities, many of which also function as long-term skilled nursing care facilities.
United States
12 Dec 2012
IRS Reaffirms Commitment To Audits Of High Net-Worth Individuals
In response to a report from TRAC criticizing its relatively new Global High Wealth Industry Group, the IRS recently reaffirmed its commitment to reviewing returns of high net worth individuals.
United States
3 Sep 2012
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