Articles / Tax Controversy and Litigation

View Search Filters
Sham Stock Sales: Acqis Technology v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/18/2024
Download the file for Sham Stock Sales: Acqis Technology v. Commissioner.
Transferee Liability under New York Law: 'Dillon Trust Co. v. United States'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 12/21/2023
Download the file for Transferee Liability under New York Law: 'Dillon Trust Co. v. United States'.
Hyatt Hotels: Are Omissions from Gross Income an Accounting Method?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 10/19/2023
Download the file for Hyatt Hotels: Are Omissions from Gross Income an Accounting Method?.
When an Expense is Considered 'Paid': 'Gage v. Commissioner'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 06/15/23
Download the file for When an Expense is Considered 'Paid': 'Gage v. Commissioner'.
Deductions for Amounts Paid by S Corporation Shareholders Fall between the Cracks
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 02/16/2023
Download the file for Deductions for Amounts Paid by S Corporation Shareholders Fall between the Cracks.
Successor Liability for Taxes: ‘ACI Construction’
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 12/15/22
Download the file for Successor Liability for Taxes: ‘ACI Construction’.
Duty of Consistency Limited: 'Belmont Interests v. Commissioner'
by David E. Kahen
Published: New York Law Journal, 10/20/2022
Download the file for Duty of Consistency Limited: 'Belmont Interests v. Commissioner'.
Deduction Versus Amortization of Start-Up Costs: 'Kellett v. Commissioner'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, 08/18/22
Download the file for Deduction Versus Amortization of Start-Up Costs: 'Kellett v. Commissioner'.
Federal Tax Guidance Overturned Under Administrative Procedure Act
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 04/21/2022
Download the file for Federal Tax Guidance Overturned Under Administrative Procedure Act.
Correlative Adjustments Denied: 'FAB Holdings v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 02/17/2021
Download the file for Correlative Adjustments Denied: 'FAB Holdings v. Commissioner'.
In Case You Missed It - August 2021 Update
by Ellen Seiler Brody
Published: Tax Stringer, 08/02/2021
Download the file for In Case You Missed It - August 2021 Update.
In Case You Missed It - July 2021 Update
by Ellen Seiler Brody
Published: Tax Stringer, 07/01/2021
Download the file for In Case You Missed It - July 2021 Update.
Equitable Estoppel Blocks Taxpayer: 'New Capital Fire v. Commissioner'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, 06/17/2021
Download the file for Equitable Estoppel Blocks Taxpayer: 'New Capital Fire v. Commissioner'.
Tax Treatment of Damages for Accountant Malpractice: McKenny v. United States
by David E. Kahen, Elliot Pisem
Published: December 28, 2020
Download the file for Tax Treatment of Damages for Accountant Malpractice: McKenny v. United States.
In Case You Missed It: October 2020
by Ellen Seiler Brody, Ellen S. Brody, JD, CPA, Esq.
Published: Tax Stringer, 10/02/2020
Download the file for In Case You Missed It: October 2020.
Helpful Instructions for Filing Domestic and Foreign Voluntary Disclosures
by Ellen Seiler Brody
Published: TaxStringer, July, 2020
Download the file for Helpful Instructions for Filing Domestic and Foreign Voluntary Disclosures.
In Case You Missed It
by Ellen Seiler Brody
Published: TaxStringer, July, 2002
Download the file for In Case You Missed It.
Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?
by Ellen Seiler Brody
Published: TaxStringer, May 1, 2020
Download the file for Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?.
Major Tax Changes in the CARES Act
by Elliot Pisem, Ellen Seiler Brody
Published: R&H Client Letter, April 10, 2010
Download the file for Major Tax Changes in the CARES Act.
Internal Revenue Service Eases Taxpayers' Audit and Compliance Burdens in Response to Coronavirus
by Elliot Pisem, Cory M. Paul
Published: R&H Client Letter, March 29, 2020
Download the file for <p>Internal Revenue Service Eases Taxpayers' Audit and Compliance Burdens in Response to Coronavirus</p>.
"Claim of Right" Update: Mihelick v. United States
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 15, 2019
Download the file for
Always Be Nice to Whistle-blowers (And Other Changes Made by the Taxpayer First Act)
by Elliot Pisem, Ellen Seiler Brody
Published: July 25, 2019
Download the file for Always Be Nice to Whistle-blowers (And Other Changes Made by the Taxpayer First Act).
S Corporation Allocations Upon Transfer of Stock
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 18, 2019
Download the file for S Corporation Allocations Upon Transfer of Stock.
S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2018
Download the file for S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'.
S Corporation Elections -- Who Decides?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2018
Download the file for S Corporation Elections -- Who Decides?.
Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Download the file for Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32.
Reliance on a CPA As Reasonable Cause: "Neanatology" Lives on After "Grecian Magnesite Mining"
by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Download the file for Reliance on a CPA As Reasonable Cause:
Is New York Overreacting on Audit and Litigation of Federal Issues?
by Joseph Lipari, Ellen Seiler Brody
Published: TaxStringer, August 1, 2017
Download the file for Is New York Overreacting on Audit and Litigation of Federal Issues?.
Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income
by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
Download the file for Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income.
Eradicating Double Non-Taxation: A Comparative Analysis of the 2016 U.S. Model Income Tax Convention and OECD/G20 BEPS Action 6
by Michael S. Grisolia
Published: Bloomberg BNA Tax Management Memorandum, November 14, 2016
Download the file for Eradicating Double Non-Taxation: A Comparative Analysis of the 2016 U.S. Model Income Tax Convention and OECD/G20 BEPS Action 6.
Managing Global Tax Controversy: A Primer for the U.S. Multinational
by Charles S. Nelson
Published: Tax Notes, July 25, 2016
Download the file for Managing Global Tax Controversy: A Primer for the U.S. Multinational.
New Partnership Audit Rules May Not Apply Until 2018, But They Are Your Headache Right Now
by Elliot Pisem
Published: To Our Clients And Friends, November 11, 2015
Download the file for New Partnership Audit Rules May Not Apply Until 2018, But They Are Your Headache Right Now.
Property Abandonment Results in Capital Loss: "Pilgrim's Pride"
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 20, 2014
Download the file for Property Abandonment Results in Capital Loss:
"Fish": Ordinary Income From Incorporation Transaction
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2013
Download the file for
Recent Domicile Determination Gives Taxpayers Reason for Optimism
by Joseph Lipari, Jason K. Binder
Published: New York Law Journal, March 8, 2013
Download the file for <p>Recent Domicile Determination Gives Taxpayers Reason for Optimism</p> .
Tax Warrants In New York
Published: 75 Albany Law Review 671, March 1 2012
Download the file for Tax Warrants In New York.
IRS Wrongly Ignores the 20 Percent Excessive Refund Penalty
Published: 138 Tax Notes 973, February 25, 2013
Download the file for IRS Wrongly Ignores the 20 Percent Excessive Refund Penalty.
More About Step Transactions: G.D. Parker v. Commissioner
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 20, 2012
Download the file for More About Step Transactions: G.D. Parker v. Commissioner.
Cracks Appear in the Code's 'Jurisdictional' Time Provisions
Published: 137 Tax Notes 511, October 29, 2012
Download the file for Cracks Appear in the Code's 'Jurisdictional' Time Provisions.
Tax Court Should Reject Twombly/Iqbal Plausibility Pleading
Published: 136 Tax Notes 853, August 13, 2012
Download the file for Tax Court Should Reject Twombly/Iqbal Plausibility Pleading.
IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad
by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
Download the file for IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad.
Taxpayer Fights Regulations, and Wins: 'Dominion Resources'
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2012
Download the file for Taxpayer Fights Regulations, and Wins: 'Dominion Resources'.
'STARS' Wars -- the Service Strikes Back at Taxpayer Claims of Privilege
by Elliot Pisem
Published: Journal of Taxation, May 01, 2012
Download the file for 'STARS' Wars -- the Service Strikes Back at Taxpayer Claims of Privilege.
An Absolute Provision Is Not Always So Absolute, Revisted -- En Banc Rehearing Brings Common Sense Back
by Ellen Seiler Brody
Published: Journal of Taxation, January 01, 2012
Download the file for An Absolute Provision Is Not Always So Absolute, Revisted -- En Banc Rehearing Brings Common Sense Back.
The Tax Court Keeps Growing Its Collection Due Process Powers
Published: 133 Tax Notes 859, September 27, 2011
Download the file for The Tax Court Keeps Growing Its Collection Due Process Powers.
IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline
by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
Download the file for IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline.
Court of Federal Claims Splits on the Computation of the TEFRA 'Jurisdictional Deposit'
by Elliot Pisem
Published: Journal of Taxation, February 01, 2011
Download the file for Court of Federal Claims Splits on the Computation of the TEFRA 'Jurisdictional Deposit'.
The Requirement For a Deficiency Notice -- When an Absolute Provision Is Not Always Absolute
by Ellen Seiler Brody
Published: Journal of Taxation, August 01, 2010
Download the file for The Requirement For a Deficiency Notice -- When an Absolute Provision Is Not Always Absolute.
Sales-Based Contingent Royalties Are Not a Production Cost Capitalized Under Section 263A
by Elliot Pisem
Published: Journal of Taxation, July 01, 2010
Download the file for Sales-Based Contingent Royalties Are Not a Production Cost Capitalized Under Section 263A.
Ruling Illustrates Treatment of Payments to Settle Litigation
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 15, 2010
Download the file for Ruling Illustrates Treatment of Payments to Settle Litigation.