Tax Controversy and Litigation Articles To Search this Article Database Enter: Key Word(s), or Code section [e.g. 162(a)], or Regulation section [e.g. 1.162-1] Corporate Taxation International Taxation Real Estate Taxation Tax Controversy and Litigation State and Local Taxation Employee Benefits Executive Compensation Estate and Personal Tax Planning All Articles     Sales-Based Contingent Royalties Are Not a Production Cost Capitalized Under Section 263A Journal of Taxation, July 01, 2010   Ruling Illustrates Treatment of Payments to Settle Litigation New York Law Journal, April 15, 2010   Tax Court Decisions on Section 6707A Penalty Deny Prepayment Forum and Extend Statute of Limitations Journal of Taxation, March 01, 2010   IRS Extends Deadline For Voluntary Disclosure Program R&H Letter to Clients and Friends, September 24, 2009   The Uncertain Boundary Between 'Partner-Level' and 'Partnership-Level' Defenses Under the Partnership Audit Rules Journal of Taxation, September 01, 2009   Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program R&H Letter to Clients and Friends, July 22, 2009   Someone Made Off With My Money, Now What? Tax Issues Affecting Ponzi Scheme Victims Journal of Taxation of Investments, July 01, 2009   The Tax Court's Surprising About-Face on the Scope of Sanctions Against the IRS for Attorney Misconduct BNA Tax & Accounting, June 25, 2008   What Happened to My Prepayment Forum? The Penalty Problem in TEFRA Partnership Audit Cases Journal of Taxation, May 01, 2008   A Tax Opinion Is Not A Bulletproof Vest The Metropolitan Corporate Counsel, November 01, 2004   The Commuter: Residents v. Non-Residents New York Law Journal, June 16, 1999   Internal Revenue Service Reconstruction and Reform Act of 1998 R & H Newsletter -- Tax Litigation & Procedure, September 01, 1998   Newsletter -- June 1998 Issue R & H Newsletter -- Tax Litigation & Procedure, June 01, 1998   Newsletter -- January 1998 Issue R & H Newsletter -- Tax Litigation & Procedure, January 01, 1998   Taxpayer Relief Act of 1997 R & H Newsletter -- Tax Litigation & Procedure, October 01, 1997   Newsletter -- February 1997 Issue R & H Newsletter -- Tax Litigation & Procedure, February 01, 1997   Newsletter -- November 1996 Issue R & H Newsletter -- Tax Litigation & Procedure, November 01, 1996