Articles / Tax Controversy and Litigation

Recent Domicile Determination Gives Taxpayers Reason for Optimism

by Joseph Lipari, Jason K. Binder
Published: New York Law Journal, March 8, 2013
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More About Step Transactions: G.D. Parker v. Commissioner

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 20, 2012
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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
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Taxpayer Fights Regulations, and Wins: 'Dominion Resources'

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2012
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'STARS' Wars -- the Service Strikes Back at Taxpayer Claims of Privilege

by Elliot Pisem, Jason K. Binder
Published: Journal of Taxation, May 01, 2012
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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
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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
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Court of Federal Claims Splits on the Computation of the TEFRA 'Jurisdictional Deposit'

by Elliot Pisem
Published: Journal of Taxation, February 01, 2011
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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
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Sales-Based Contingent Royalties Are Not a Production Cost Capitalized Under Section 263A

by Elliot Pisem, Jason K. Binder
Published: Journal of Taxation, July 01, 2010
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Ruling Illustrates Treatment of Payments to Settle Litigation

by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 15, 2010
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BLAK Affirms the Necessity of Raising Statute of Limitations Defense Early in TEFRA Partnership Proceedings

by Elliot Pisem, Jason K. Binder
Published: Journal of Taxation, April 01, 2010
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IRS Issues Relief from FBAR Filing Obligations for Three Groups

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
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IRS Extends Deadline For Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
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Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
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Someone Made Off With My Money, Now What? Tax Issues Affecting Ponzi Scheme Victims

by Mark E. Wilensky, David Schectman, Lelia Fusfeld
Published: Journal of Taxation of Investments, July 01, 2009
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What Happened to My Prepayment Forum? The Penalty Problem in TEFRA Partnership Audit Cases

by Elliot Pisem
Published: Journal of Taxation, May 01, 2008
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A Tax Opinion Is Not A Bulletproof Vest

by Richard A. Levine
Published: The Metropolitan Corporate Counsel, November 01, 2004
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The Commuter: Residents v. Non-Residents

by , Glenn Newman
Published: New York Law Journal, June 16, 1999

Internal Revenue Service Reconstruction and Reform Act of 1998

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, September 01, 1998

Newsletter -- June 1998 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, June 01, 1998

Newsletter -- January 1998 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, January 01, 1998

Taxpayer Relief Act of 1997

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, October 01, 1997

Newsletter -- February 1997 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, February 01, 1997

Newsletter -- November 1996 Issue

by Richard A. Levine, Carlton M. Smith
Published: R & H Newsletter -- Tax Litigation & Procedure, November 01, 1996