Adult Club Dancers/Tenants Are Independent Contractors
Adult Club Dancers/Tenants Are Independent Contractors ...
Letter Ruling 200141036
The IRS found that certain payments made under a divorce instrument qualify as alimony under IRC Sec. 71 and 215 for Federal tax purposes. The taxpayer entered into a settlement agreement with the former spouse to provide cash payments in exchange for th ...
Letter Ruling Considers Whether Payments Are Alimony
The IRS found that certain payments made under a divorce instrument qualify as alimony under IRC Sec. 71 and 215 for federal tax purposes.
Reasonable Compensation Based on Surveys Rejected
The Tax Court considered expert testimony regarding reasonable compensation deductions.
B & D Foundations, Inc. v. CIR
The Tax Court considered expert testimony regarding reasonable compensation deductions. Both parties’ experts based their conclusions on data from RMA, Watson Wyatt, the Conference Board, or studies they performed. The court rejected their conclusions bec ...
Gow v. Commissioner (II)
At issue is whether that the Tax Court improperly val-ued the plaintiff's shares of stock in Williamsburg Vacations, Inc. ("WVI") for tax purposes.
4th Circuit Affirms Gow v. Commissioner
This income tax case was appealed from the U.S. Tax Court. (The lower court case was abstracted in the May 2000 issues of both BVU and J&L ...
REG-107151-00
The IRS proposed regulations to clarify the application of IRC sec. 1041. They apply only to stock redemption in which the non-transferor spouse directly owns stock in the redeeming corporation immediately before or after the redemption. The regulation ...
Proposed Regulations Clarify Application of IRC Sec. 1041
The IRS proposed regulations to clarify the application of IRC sec. 1041.
Experts Rejected as Advocates
The Tax Court considered the amount of reasonable and deductible compensation of two shareholders.
Wagner Construction, Inc. v. CIR
The Tax Court considered the amount of reasonable and deductible compensation of two shareholders. The expert for both parties used diverse methods to arrive at positions supporting their respective parties. The Tax Court found that the testimony of the e ...
Interest Received on Property Distribution Is Income
The Tax Court considered whether payments received from a former spouse were includible in the petitioner’s gross income under IRC sec. 61.
Andrea Cipriano v. CIR
The Tax Court considered whether payments received from a former spouse were includible in the petitioner’s gross income under IRC sec. 61. She argued that the payments were excludable under IRC sec. 1041, because they were for the future appreciation of ...
Tax Court Bemoaned Lack of Expert Testimony
The Tax Court considered whether the compensation a holding company paid to its shareholder, a husband and wife, was reasonable and deductible under IRC Sec. 162.
Metro Leasing and Development Corporation, East Bay Chevrolet Company v. CIR
The Tax Court considered whether the compensation paid by a holding company to its shareholder, a husband and wife, was reasonable and deductible under IRC Sec. 162.
Eberl's CLaim Service, Inc. v. CIR
The U.S. Court of Appeals for the Tenth Circuit considered whether the amount a catastrophic claims adjusting company paid its sole shareholder was reasonable and deductible under IRC Sec. 162. The court affirmed the Tax Court’s reasoning under a multi-fa ...
James Tinnell v. CIR
The U.S. Tax Court determined a taxpayer liable for accuracy related penalties when he failed to disclose his application of a lack of marketability discount in a disclosure form 8275. The court found that the plaintiff did not have the stock valued or re ...
Reasonable Compensation Considered
The U.S. Court of Appeals for the 10th Circuit considered whether the amount a catastrophic claims adjusting company paid its sole shareholder was reasonable and deductible under IRC Sec. 162.
Restricted Stock Discount Must Be Adequately Disclosed
The U.S. Tax Court determined a taxpayer liable for accuracy-related penalties when he failed to disclose his application of a lack of marketability discount in a disclosure form 8275.
Conrad George Olsen v. CIR
The Tax Court concluded that the payment of an equitable distribution award by the purchaser of property awarded to the taxpayer in a divorce did not qualify for IRC Sec. 1041 nonrecognition treatment because the transaction did not meet the requirements ...
Third-Party Transaction Not Available for Nonrecognition Treatment
The Tax Court concluded that the payment of an equitable distribution award by the purchaser of property awarded to the taxpayer in a divorce did not qualify for IRC Sec. 1041 nonrecognition treatment.
9th Circuit Affirms Tax Court Reasonable Compensation Ruling
This decision affirms the Tax Court case abstracted in the December 1998 BVU, p. 5.
Thompson v. United States
At issue is the admittance of expert testimony.
Reliance on Expert Upheld
Plaintiff invested in Davenport Recycling Associates limited partnership, which turned out to be (without plaintiff's knowledge at the time) a sham transaction.
LabelGraphics, Inc. v. Commissioner (II)
At issue is the determination of reasonable employee compensation for deduction as an ordinary and necessary business expense.