In Suder v. Commissioner, T.C. Memo. 2014-201, the U.S. Tax Court considered whether the taxpayer’s research was qualified and whether the wage expenses paid to Sunder were reasonable for purposes of the research tax credit. Suder was the founder and …..
In Cooper v. Commissioner, 143 T.C. 10, the U.S. Tax Court concluded that a business owner was not entitled to a bad debt deduction for a loan made to a failing business prior to the time the business actually failed. …..
The IRS issued Action on Decision 2014-01 to put taxpayers on notice that it would not follow a court case in which the court did not allow the IRS to apply voluntary tax payments to the business’ employment tax liabilities …..
In Bergdale v. Commissioner, T.C. Memo. 2014-152, the U.S. Tax Court concluded that the IRS did not abuse its discretion in rejecting an offer-in-compromise that was not submitted on a Form 656, even though it appears that the IRS and …..
In Miller v. Commissioner, T.C. Summary Opinion 2014-74, the U.S. Tax Court concluded that a public relations director was not liable for accuracy-related penalties under Section 6662(a) for relying on her husband as the tax preparer. The facts and procedural …..
In Eichler v. Commissioner, 143 T.C. 2, the U.S. Tax Court said that the IRS Notice of Intent to Levy was proper even though the IRS failed to follow its policy to check an installment request into its system which …..
The IRS released a memo describing Phase II of the Appeals Judicial Approach and Culture (AJAC) program. This program is intended to formalize many of the best practices of the IRS Office of Appeals (Appeals). Tax disputes often end up …..