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Tax Court deals another blow to cannabis dispensaries

In recent years, numerous cannabis businesses that are legal under state law have unsuccessfully challenged section 280E of the Internal Revenue Tax Code, which prohibits tax deductions for a business that “consists of” trafficking in a controlled substance.

Mission Critical in Divorce: 10 Key Insights in 50 Minutes-a Free AAML/BVR Virtual Divorce Conference Preview

Brought to you by the American Academy of Matrimonial Lawyers (AAML) and Business Valuation Resources (BVR), this free preview for the Virtual Divorce Conference brings together attorneys, valuation professionals, and industry experts in a one action-packed, 60-minute session. Get short compelling lessons that you need to know now. This year’s conference focuses on the topics most impacted by divorce, and anyone serving business owners involved in matrimonial dissolution can get access to this premium preview ...

Structure, Valuation & Tax Insights for Logistics & Trucking Companies

Join Jaclyn Burket Frank and Ricky Castillo for an engaging trip into the world of logistics and trucking businesses. Discover the different types of entity structure along with the advantages and disadvantages of each structure. Learn how the 2018 tax law impacted each entity structure and common deductible/nondeductible expenses for the logistics and trucking industry. The industry-specific adjustments to consider along with specific questions to ask business owners to determine whether economic, governmental, and location ...

Court upholds Section 1031 tax ruling, affirming appraisals were unreliable

In 2016, the U.S. Tax Court found for the Internal Revenue Service in a dispute over a series of exchanges that Exelon, the tax payer, designated as section 1031 transactions. The court found these were not like-kind exchanges and expressed dismay over the appraisals the tax payer offered to support its claim for significant deductions.

Tax Court Favors IRS’s Cost Markup Analysis to Compute Management Fee

In a suit over fees paid by taxpayers’ operating companies to taxpayer-controlled management company, Tax Court says IRS expert’s cost markup analysis produces most credible arm’s-length management fee; this fee represents the allowable deduction amount.

Wycoff v. Commissioner

In a suit over fees paid by taxpayers’ operating companies to taxpayer-controlled management company, Tax Court says IRS expert’s cost markup analysis produces most credible arm’s-length management fee; this fee represents the allowable deduction amount.

Compromised Section 1031 appraisal sinks Exelon tax strategy for fossil fuel power plant sale

U.S. Tax Court Judge David Laro frequently has cautioned experts not to give in to hiring attorneys who want to shape the appraisal. Although federal and state discovery rules offer some protection for attorney-expert communication, there is a risk of exposure and with it a risk of damage to the expert’s work product and reputation. A recent Section 1031 case, which Judge Laro handled, illustrates what happens when the communication is discovered.

Return on Equity Analysis Undergirds Reasonable Compensation Claim

Tax Court says compensation paid to company owners for managing entity’s daily operations was reasonable; officers were “absolutely integral” to company’s success and company’s rate of return on equity after compensation accorded with industry average.

H.W. Johnson v. Commissioner

Tax Court says compensation paid to company owners for managing entity’s daily operations was reasonable; officers were “absolutely integral” to company’s success and company’s rate of return on equity after compensation accorded with industry average.

Court Approves Winstar Plaintiff’s Tax Gross Up Calculation

Court finalizes damages award to Winstar bank by adopting plaintiff’s projected tax liability on damages related to government’s breach of contract and by ordering an additional gross up award “to make plaintiff whole.”

Obsolescence Analysis Kills Tax Court’s Property Valuation

State high court rejects tax court’s external obsolescence calculation related to special purpose property valuation, finding it represents an insufficiently explained departure from the methods the parties’ experts used and lacks support in the record.

Anchor Savings Bank v. United States

Court finalizes damages award to Winstar bank by adopting plaintiff’s projected tax liability on damages related to government’s breach of contract and by ordering an additional gross up award “to make plaintiff whole.”

Guardian Energy, LLC v. County of Waseca

State high court rejects tax court’s external obsolescence calculation related to special purpose property valuation, finding it represents an insufficiently explained departure from the methods the parties’ experts used and lacks support in the record.

Use of Asset-Level Deductions Hinges on Business Strategy

State’s high court strikes down district court’s fair value determination, finding reliance on prior law prohibiting use of deductions was misguided where company pursued strategy of selling off real estate and other assets at time of triggering event.

Utah Resources International, Inc. v. Mark Technologies Corp.

State’s high court strikes down district court’s fair value determination, finding reliance on prior law prohibiting use of deductions was misguided where company pursued strategy of selling off real estate and other assets at time of triggering event.

Taxpayer Scores Partial Success in Cal. Hotel Property Tax Suit

Appeals court says assessor’s version of income approach to determine hotel property taxes violates law because it does not identify, value, and exclude certain intangible assets; but management fee deduction largely captures hotel’s goodwill.

SHC Half Moon Bay, LLC v. County of San Mateo

Appeals court says assessor’s version of income approach to determine hotel property taxes violates law because it does not identify, value, and exclude certain intangible assets; but management fee deduction largely captures hotel’s goodwill.

Mulcahy, Pauritsch, Salvador & Co. v. Commissioner

Tax Court says, under independent investor test, taxpayer is not entitled to presumption that deductions for “consulting fees” are reasonable compensation; firm’s expert relied on irrelevant statistics to support reasonable compensation for services claim ...

Foreign-Educated Doctor’s Lost Earnings Computed in Personal injury Action

In Dr. Natheir Al-Hendawi v. Manjit Singh Sidhu, 2006 BCSC 522 (CanLII) (decided March 30, 2006), the Supreme Court of British Columbia calculated. the lost past and future earnings of a medical doctor resulting from an auto accident.

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