DarrowEverett LLP’s Post

From owing $51,000 to receiving a refund? 🤔 That's the power of skillful tax representation! 👌🏻 My client initially filed for a refund, but the IRS issued a Notice of Deficiency. 👀 We fought back in the Tax Court, and the judge ruled in our favor, not only eliminating the debt but securing a refund! 👈🏻 This win proves that the right legal representation can make a HUGE difference. ✅ #TaxCourt #TaxVictory #IRS #TaxAttorney #TaxRefund #NoticeOfDeficiency #TaxLaw

This is an excellent summary and analysis of the law. But I noted that there is nothing in this excellent analysis that questions whether Treasury and the IRS should be acting as tax administrator looking to provide the best answer or whether Treasury and the IRS should act as advocates for a legal position. I wrote in Tax Notes about five years back that Treasury has developed a habit of failing to cite, mention or distinguish contrary or arguably contrary authority. The IRS is not a "tribunal" upon which the ABA Model Rules of Professional Conduct impose such a requirement upon opposing counsel. But shouldn't the IRS adopt best practices or must Congress amend the APA to require it. See https://lnkd.in/gQVPG43S. Tax Notes

#Tax attorney Lee Meyercord will join other tax professionals on a panel at the Tax Executives Institute 79th Annual Conference in #SanAntonio. Lee's panel will focus on the #IRS' growing use of the codified economic substance doctrine and related judicial doctrines to challenge #transactions. She will analyze recent cases and explore the potential for a "relevance" test for applying these doctrines. Click here to register: https://bit.ly/3z1PAL1 #taxcontroversy

The TaxProf: The Top Five New Tax Papers: There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with new papers debuting on the list at #3, #4, and #5. [889 Downloads] Don't Blame the Victims: Individuals and the MRT, by Karen Alpert (FixTheTaxTreaty.org), John Richardson (TaxResidentAbroad.com) & Laura... http://dlvr.it/T7jz9b @SoCalTaxProf #Tax #Policy #Law

The TaxProf: The Top Five New Tax Papers: There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with new papers debuting on the list at #3, #4, and #5. [889 Downloads] Don't Blame the Victims: Individuals and the MRT, by Karen Alpert (FixTheTaxTreaty.org), John Richardson (TaxResidentAbroad.com) & Laura... http://dlvr.it/T7jzB6 @SoCalTaxProf #Tax #Policy #Law

In a recent decision, the Tax Appeals Tribunal has held that filing documentary evidence without specifying exactly how the documentary evidence supports your statement of facts is akin to leaving the Tribunal to prosecute your appeal. Although brevity is a virtue, it seemingly is not one on account of pleadings in tax matters. Annexing of (bulky) documents to a statement of facts without demonstrating how they support your case at the Tribunal is a mere academic exercise - their relevancy notwithstanding. Don't be very brief. At the very least, be thorough. #tax

In Tax Notes, Lowenstein partner Melissa Wiley says that despite the U.S. District Court for the Eastern District of Texas ruling the Corporate Transparency Act unconstitutional, her advice to clients remains unchanged, as she anticipates an appeal and highlights ongoing cases in other federal courts with opposing views. Wiley also shares her perspective in Reuters' Checkpoint, advising clients to continue complying with the law despite the injunction. Read the Tax Notes article: https://bit.ly/41lrjuW Read the Checkpoint article: https://bit.ly/4f5auYk Read Melissa’s bio: https://lnkd.in/erQy3Z3J #corporatetransparencyact #taxlaw #beneficialownership #financialregulations #womeninlaw

#BusinessLawToday | A recent US Tax Court case highlights how only certain private delivery services meet IRS guidelines for exceptions to the timely filing rule. Read: https://lnkd.in/dna_7BnK #BusinessLaw #BusinessRegulation #RegulatedIndustries

The IRS claimed Sally Anenberg’s estate owed millions in gift taxes after the termination of marital trusts and subsequent transfer of business shares. But the Tax Court disagreed, ruling that no taxable gift was made. Key takeaways from this case: ✅ Trust terminations can spark IRS scrutiny. ✅ Gift tax laws hinge on precise legal definitions. ✅ The Tax Court's decision could set a precedent for similar disputes. Should the IRS have the authority to impose gift taxes in cases like this, or was the court correct? Let’s discuss. #TaxLaw #GiftTax #EstatePlanning #TaxCourt #IRSUpdates #MaritalTrusts #TaxDebate #FinancialLaw #TrustsAndEstates #LegalDisputes #WealthManagement #TaxCase #TaxationMatters #EstateTax #TaxPlanning #IRSNews #TaxLitigation #TrustsLaw #TaxJustice #WealthTransfer #IRSControversy #TaxLawInsights #EstateManagement #TaxTips #TaxPolicy #IRSDecisions #LegalInsights #TaxReform #CourtRulings #FinancialPlanning

On June 28, 2024, the U.S. Supreme Court issued a landmark decision in 𝘓𝘰𝘱𝘦𝘳 𝘉𝘳𝘪𝘨𝘩𝘵 overturning the 40-year-old 𝘊𝘩𝘦𝘷𝘳𝘰𝘯 doctrine. The Court concluded that a reviewing court should not defer to an agency’s interpretation of a statute solely because it is ambiguous. This decision significantly alters the landscape of administrative law, casting uncertainty on the level of deference that tax regulations, which have long benefited from 𝘊𝘩𝘦𝘷𝘳𝘰𝘯 deference, will receive going forward. Read the full analysis from our tax experts here: https://okt.to/VptuHW #AMon #taxalert #nationaltax #legalupdate Kevin M. Jacobs, Charles W. Cope, Bill Seaway, Emily Leebron Foster, Ernesto Perez, Adam Benson, Tyler Horton, Logan M. Kincheloe