In Polselli v. IRS, the Supreme Court was tasked with determining whether the IRS, pursuant to powers granted in Internal Revenue Code (IRC) section 7609(c)(2)(D)(i), is entitled to issue third-party summonses, without notice, for bank account records in which the taxpayer targeted by the summons does not have a legal interest.
Continue Reading Supreme Court Affirms IRS Power to Summons Bank Information Without Notice to Delinquent Taxpayer
On May 9, 2023, just four days after oral argument before the circuit court, the Supreme Court of Maryland issued a Mandate, vacating the circuit court’s order granting the
Continue Reading Maryland’s Digital Advertising Gross Revenues Tax Not Dead (Yet)
On April 7, 2023, the Second District of the California Court of Appeal published a landmark opinion on California property tax law that expands the tax-exempt status of intangible assets
Continue Reading California Court of Appeal Landmark Opinion Expands Intangible Asset Exemption from Property Tax Assessment
The proposed regulations demonstrate that the IRS is taking a proactive approach in addressing the APA challenges to its method for identifying listed transactions. The IRS makes clear that it will continue to aggressively pursue syndicated conservation easement transactions.
Continue Reading Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions
The Commonwealth Court of Pennsylvania recently held in Online Merchants Guild v. Hassell that the Pennsylvania Department of Revenue failed to provide sufficient evidence that non-Pennsylvania businesses selling merchandise through
On Oct. 3, 2022, the U.S. Supreme Court granted certiorari in In Re Grand Jury. On appeal from the Ninth Circuit, In Re Grand Jury considers whether the attorney-client
Continue Reading U.S. Supreme Court Grants Certiorari in Case Involving Application of Attorney-Client Privilege to Dual-Purpose Communications with Tax Attorneys
The contours of plaintiff pleading requirements for ERISA fiduciary breach claims sketched by the Supreme Court in Hughes v. Northwestern University continue to evolve. Recent cases suggest that plaintiffs may
Continue Reading The Tide May Be Turning on Flood of ERISA Excessive Fee Class Actions
In a major change in New York’s law on statutory residency, in a June 30 ruling in Obus v. New York State Tax Appeals Tribunal, the New York State
Continue Reading Greenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory Residency
On May 13, 2022, in Reserve Mechanical Corporation v. Commissioner,[1] the U.S. Court of Appeals for the Tenth Circuit affirmed a Tax Court decision that a micro-captive insurance
Continue Reading Another Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. Commissioner
In a rare change of position, on June 2, 2022, the district court granted the government’s motion in CIC Services, holding the IRS was not required to return the
Continue Reading District Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66