Articles / Tax Controversy and Litigation

S Corporation Inconsistent Reporting Issues: 'Rubin v. United States'

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, October 18, 2018
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S Corporation Elections -- Who Decides?

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, June 21, 2018
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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
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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
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Is New York Overreacting on Audit and Litigation of Federal Issues?

by Joseph Lipari, Ellen Seiler Brody
Published: TaxStringer, August 1, 2017
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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
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Eradicating Double Non-Taxation: A Comparative Analysis of the 2016 U.S. Model Income Tax Convention and OECD/G20 BEPS Action 6

by Nancy Chassman, Michael S. Grisolia
Published: Bloomberg BNA Tax Management Memorandum, November 14, 2016
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Managing Global Tax Controversy: A Primer for the U.S. Multinational

by Nancy Chassman, Charles S. Nelson
Published: Tax Notes, July 25, 2016
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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
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Property Abandonment Results in Capital Loss: "Pilgrim's Pride"

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, February 20, 2014
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"Fish": Ordinary Income From Incorporation Transaction

by Elliot Pisem, David E. Kahen
Published: New York Law Journal, December 19, 2013
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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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Tax Warrants In New York

Published: 75 Albany Law Review 671, March 1 2012
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IRS Wrongly Ignores the 20 Percent Excessive Refund Penalty

Published: 138 Tax Notes 973, February 25, 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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Cracks Appear in the Code's 'Jurisdictional' Time Provisions

Published: 137 Tax Notes 511, October 29, 2012
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Tax Court Should Reject Twombly/Iqbal Plausibility Pleading

Published: 136 Tax Notes 853, August 13, 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
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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The Tax Court Keeps Growing Its Collection Due Process Powers

Published: 133 Tax Notes 859, September 27, 2011
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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
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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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 , 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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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