Taxpayers’ Brief Filed in Woods
The taxpayers have filed their response brief in the Supreme Court in the Woods case, contending first that the courts lacked jurisdiction to impose the penalties requested by the IRS and, second,...
View ArticleBriefing Complete in Woods
The government has filed its reply brief in the Supreme Court in Woods. See our reports on the opening briefs here and here. The discussion of the jurisdictional issue focuses less on the textual...
View ArticleNPR Court Asks Parties for Additional Information on Jurisdictional Questions
It has been almost two years since the Fifth Circuit heard oral argument in the NPR Investments case, which involves a “son-of-BOSS” tax shelter and associated questions regarding penalties and...
View ArticleSupreme Court Struggles to Unravel TEFRA Jurisdiction in Woods Oral Argument
The Supreme Court held oral argument in United States v. Woods on October 9. As we have previously reported, the case presents two distinct questions: (1) a TEFRA jurisdictional question concerning...
View ArticleSupreme Court Rules for Government on Both Issues in Woods
The Supreme Court this morning ruled 9-0 in favor of the government on both issues in Woods, holding that: (1) there is partnership-level TEFRA jurisdiction to consider the appropriateness of a...
View ArticleFifth Circuit Upholds Penalties in NPR
The Fifth Circuit has finally issued its opinion in NPR (as reflected in our prior coverage, this case was argued almost two years ago), a case involving a Son-of-BOSS tax shelter in which the district...
View ArticleDivided Tax Court Decides E&P Computation Issue in Eaton
In Eaton Corp. v. Commissioner, 152 T.C. No. 2 (2019), a divided Tax Court decided (by a 10-2 margin) that the CFC partners in a U.S. partnership must increase earnings and profits (E&P) for the...
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