Revocation of Tax Election by Non-Debtor Declared Void
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 19, 2012
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Accrual of Deduction for Disputed Amount
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, February 16, 2012
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The Wizard of Broz: S Corporations, Economic Outlay, and Debt Basis
by Elliot Pisem
Published: Journal of Taxation, February 01, 2012
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Warrants and Tax Avoidance Motivation Prove Hazardous
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 20, 2011
Download the file for Warrants and Tax Avoidance Motivation Prove Hazardous.
The New Voluntary Disclosure: No, It's Not For Those Hidden Foreign Bank Accounts -- This Time It's For Employers Who Need to Reclassify Their Workers As Employees
by Norman J. Misher, Allen J. Erreich, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, October 19, 2011
Download the file for The New Voluntary Disclosure: No, It's Not For Those Hidden Foreign Bank Accounts -- This Time It's For Employers Who Need to Reclassify Their Workers As Employees.
Noncompetition Covenants: 'Recovery Group v. Commissioner'
by David E. Kahen, Elliot Pisem
Published: New York Law Journel, August 18, 2011
Download the file for Noncompetition Covenants: 'Recovery Group v. Commissioner'.
'And If Tommy Told You To Jump Off The Brooklyn Bridge?' - Taxpayers Follow Advice Straight Into An Accuracy Penalty
by Elliot Pisem
Published: Journal of Taxation, July 01, 2011
Download the file for 'And If Tommy Told You To Jump Off The Brooklyn Bridge?' - Taxpayers Follow Advice Straight Into An Accuracy Penalty.
Transferee Liability: Recent Developments
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 21, 2011
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Substance Over Form - 'WB Acquisitions'
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, February 17, 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
Download the file for Court of Federal Claims Splits on the Computation of the TEFRA 'Jurisdictional Deposit'.
Reliance On Tax Opinion May Not Prevent Penalties
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 16, 2010
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Lack of Consistency in S Corporation Reporting -- How Onerous Are the Results?
by Elliot Pisem
Published: Journal of Taxation, December 01, 2010
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Rules Address Reporting of Securities Transactions
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 21, 2010
Download the file for Rules Address Reporting of Securities Transactions.
Tax Court Decision Clarifies Treatment of Built-In Gain
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 19, 2010
Download the file for Tax Court Decision Clarifies Treatment of Built-In Gain.
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.
What is (Not) Income? Nathel v. Commissioner
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, June 17, 2010
Download the file for What is (Not) Income? Nathel v. Commissioner.
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
Published: Journal of Taxation, April 01, 2010
Download the file for BLAK Affirms the Necessity of Raising Statute of Limitations Defense Early in TEFRA Partnership Proceedings.
Tax Court Decisions on Section 6707A Penalty Deny Prepayment Forum and Extend Statute of Limitations
by Elliot Pisem
Published: Journal of Taxation, March 01, 2010
Download the file for Tax Court Decisions on Section 6707A Penalty Deny Prepayment Forum and Extend Statute of Limitations.
Roberts & Holland: Creative Tax Solutions to Complex Business Problems
Published: Forbes, January 18, 2010
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Drawing a Line -- Information Reporting vs. Malicious Gossip
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 17, 2009
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IRAs Barred From Owning Stock in S Corporation
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 15, 2009
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Gratuitous Transfer to Related Partnership Not a 'Distribution'
by David E. Kahen
Published: New York Law Journal, June 18, 2009
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Loss Carryovers and Carrybacks When Only Part of a Consolidated Group is Bankrupt: The Garbled Message of PT-1 Communications
by Elliot Pisem
Published: Journal of Taxation, June 01, 2009
Download the file for Loss Carryovers and Carrybacks When Only Part of a Consolidated Group is Bankrupt: The Garbled Message of PT-1 Communications.
Court Addresses 'Reasonableness' of Compensation
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 16, 2009
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Allocations of Consideration for a Closely Held Business - Muskat v. United States
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 18, 2009
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Private Equity Fund Found Liable for Pension Obligation of Bankrupt Portfolio Company
by Norman J. Misher
Published: The Journal of Private Equity, January 01, 2009
Download the file for Private Equity Fund Found Liable for Pension Obligation of Bankrupt Portfolio Company.
Proposed Regulations Clarify Penalty Taxes on Income Inclusions
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 18, 2008
Download the file for Proposed Regulations Clarify Penalty Taxes on Income Inclusions.
Ruling Highlights Importance of Drafting to Indemnification
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 16, 2008
Download the file for Ruling Highlights Importance of Drafting to Indemnification.
New Legislation Penalizes Deferred Compensation from Certain Foreign Corporations and Partnerships
by David E. Kahen, Norman J. Misher
Published: R&H Letter to Clients and Friends, October 15, 2008
Download the file for New Legislation Penalizes Deferred Compensation from Certain Foreign Corporations and Partnerships.
Decisions Underline Scope of IRS Summons Power
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 21, 2008
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Shareholder Disputes Give Rise to Tax Disputes
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, June 19, 2008
Download the file for Shareholder Disputes Give Rise to Tax Disputes.
The Short-Term Deferral Rule Can Mitigate the Impact of Section 409A
Published: R&H Letter to Clients and Friends, June 11, 2008
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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
Download the file for What Happened to My Prepayment Forum? The Penalty Problem in TEFRA Partnership Audit Cases.
Forfeiture of Deductions for Failure to File Timely Return: (Swallows Holding, Ltd. v. Commissioner)
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, April 17, 2008
Download the file for Forfeiture of Deductions for Failure to File Timely Return: (Swallows Holding, Ltd. v. Commissioner).
Time To Comply With Section 409A Is Running Out
Published: R&H Letter to Clients and Friends, April 02, 2008
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Ernst & Young: When Must Stocks Be Taken Into Income?
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 21, 2008
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Ruling Has Not Resolved Work-Product Privilege Issue
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, October 18, 2007
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Recent Developments Related To Nontaxable Spinoffs
by Elliot Pisem, David E. Kahen
Published: The New York Law Journal, August 16, 2007
Download the file for Recent Developments Related To Nontaxable Spinoffs.
Warrants Not Received 'In Connection With' Performance of Services
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, June 21, 2007
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The Burden of Persuasion in Tax Litigation
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 21, 2006
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Court Addresses Limitations on Pass-Through of Losses
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, August 17, 2006
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Applying Section 162(m) To Partnership Remuneration
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, April 20, 2006
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State Corporate Income Taxes No Longer Make Sense
by , Carolyn Joy Lee
Published: State Tax Notes, April 17, 2006
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When Is A Contract An Option?
by David E. Kahen, Elliot Pisem
Published: New York Law Journal, December 15, 2005
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Gain Clarified in Shareholder Loans to S Corporations
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 20, 2005
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Is Evading Foreign Taxes A U.S. Crime?
Published: The Metropolitan Corporate Counsel, September 01, 2005
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Impact of Securities Laws on Taxation of Compensation
by Elliot Pisem, David E. Kahen
Published: New York Law Journal, August 18, 2005
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IRS Shines Spotlight On Executive Compensation Practices
by David E. Kahen
Published: The Metropolitan Corporate Counsel, July 01, 2005
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