Certain types of tax disputes seem to arise again and again year after year. By way of example, for the past several years the US Tax Court has heard several cases involving injury settlement awards that were not properly structured. …..
Civil tax cases often turn into criminal tax cases. In those instances the IRS initially investigates the tax crime and then refers the case to the Department of Justice. The IRS efforts to investigate the potential tax crime often require …..
Estate & Trust Attorneys Will Increasingly be Subject to Malpractice Actions Brought by Beneficiaries
It is now well established that a plaintiff s attorney should be subject to malpractice liability for not proposing a structured settlement annuity versus a lump sum payment to their injured clients and for not seeking the advice and assistance …..
As with other advisors, tax attorneys often find themselves taking contrary positions on the same law in different cases. These situations can be difficult. The professional rules governing attorneys conduct address this. The more challenging situations for attorneys arise when …..
Businesses often succumb to the temptation to use taxes withheld from employees’ salaries to overcome cash flow problems. Unfortunately these types of “government loans” are often fatal to the business and the “responsible persons” financial well being. The resulting tax …..
Many tax practitioners agree that valuing property for tax purposes is the most important issue that they face. Yet valuation issues are often murky and amorphous. In most cases valuation disputes are resolved in favor of the party that has …..
I was wondering how the tax code complexity debate had progressed while I was away. So it appears that the blogosphere keeps going even when I am not here (sorry, it’s just one of those “what if a tree falls …..