Taxpayer Victory in 9th Circuit Family LLC Case
9th Circuit reverses district court’s summary judgment in favor of the government in family LLC case, finding that the step transaction did not apply and remanding the case for findings regarding when the gift was transferred.
Estate of Mitchell v. Commissioner
Tax Court sides with estate and holds proper method for valuing 100% leased-fee interests of real property is income capitalization method, rather than lease buyout method proposed by respondent’s expert.
Can the IRS subpoena your work papers, even after the taxpayers have paid the deficiency?
An Idaho couple claimed nearly $1.5 million as a charitable contribution deduction on their federal tax returns relating to the granting of a conservation easement. The IRS summoned the taxpayer’s appraiser to provide evidence related to the easement valuation, including all his work files. Based on advice of the taxpayer’s attorney, the appraiser refused the summons, asserting the attorney-client privilege and work-product protections.
Linton v. United States
Ninth Circuit reverses district court’s summary judgment in favor of the government in family LLC case, finding that the step transaction did not apply and remanding the case for findings regarding when the gift was transferred.