On April 3, 2023, the U.S. Tax Court ruled in Farhy v. Commissioner[1] that the IRS lacks statutory authority to assess Form 5471 penalties under I.R.C. § 6038(b)(1) or
Continue Reading IRS Lacks Statutory Authority to Assess International Information Return Penalties: U.S. Tax Court
In Green Valley Investors, LLC, Et Al., Bobby A. Branch, Tax Matters Partner, v. Commissioner, the Tax Court on Nov. 9 abated Internal Revenue Code (I.R.C.) § 6662A penalties
Continue Reading U.S. Tax Court Invalidates Conservation Easement Notice, Abates Reportable Transaction Penalty for Failure to Comply with Administrative Procedure Act
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
On April 9, 2021, the IRS urged taxpayers who engage in micro-captive insurance arrangements to exit these transactions. This announcement follows an IRS victory in the U.S. Tax Court, which
Continue Reading IRS Wins Again on Micro-Captive Arrangements, Urges Taxpayers to Exit Transactions
The IRS Office of Chief Counsel announced in Issue Number IR-2020-130 that it will be making a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving
Greenberg Traurig Shareholder Seth Entin was recently quoted in Accounting Today for an article on a recent IRS Ruling in the U.S. Tax Court. In July, the U.S. Tax Court
Continue Reading Greenberg Traurig’s Seth Entin Quoted in Accounting Today on Recent IRS Ruling