Our tax laws seem to evolve (devolve?) over time. This evolution seems to follow a pretty predictable pattern. I will use Action on Decision 2005-001, which is an interesting decision in and of itself, to describe this process. In this …..
Clients often ask me whether the IRS takes steps to slant the facts and law in the governments favor. I often explain that, as with most legal matters, there is really no right or wrong answer until the court makes …..
The US tax court has somewhat of a controversial history, as far as courts go. The court, initially named the board of tax appeals, fell under the aegis of the executive branch of the federal government. The court underwent two …..
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 …..