CARES Act – The $2.2 Trillion Stimulus Package

On Friday, March 26, 2020, history was made. In one fell swoop, Congress dropped $2.2 trillion to keep the United States’ economy going during the COVID-19 epidemic with the passage of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). With such a lengthy bill, many are wondering what all is contained in the…
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Recent Conservation Easement Attacks by the IRS

Conservation has been in the tax news yet again recently. Really, ever since Notice 2017-10, conservation easements, especially those of the syndicated variety, have been caught in the cross hairs of the IRS as well as the Department of Justice while also drawing the ire of a few of those in power in Congress. Most…
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Postmark Rule 180 in Refund Case Ruling – Harrison

In a recent case out of the U.S. District Court in Wisconsin, the Court granted a motion to reconsider its previous ruling in favor of the government (filed by the IRS) in a case involving the postmark rule. Additionally, the IRS was the recipient of some pretty strong criticism from the Court. So much so,…
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MCM Investment Management LLC – Related Parties and a Worthless Interest Deduction

In a recent taxpayer-favorable case, the Tax Court upheld a loss deduction for a worthless investment under Code Section 165. At issue was an interest held by a partnership in a related family-owned real estate development business. The taxpayer, MCM Investment Management LLC (“MCM”) alleged its interest in McMillin Companies, LLC (“InvestCo”), a real estate…
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IRS Leaves $155.5 Million Lump of Coal for Faulty Easement Deed

On October 28, 2019, the Tax Court released its opinion in Coal Property Holdings, LLC v. Comm’r, 153 T.C. No. 7 (2019). This case comes at a sensitive time of year where deadlines are looming in order to file conservation deeds to qualify for the deduction under Section 170(h), relating to qualified conservation contributions, for…
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Tales from the Crypto: Rev. Rul. 2019-24 and New FAQs Released by IRS

On October 9, 2019, the Internal Revenue Service (“IRS”) released its latest buzzkill, Rev. Rul. 2019-24, answering questions involving hard forks of cryptocurrency, which, as explained more below, is where a new type of cryptocurrency is created and there is a permanent diversion from legacy currency or existing distributed ledger. In conjunction with the release…
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IRS Stirring the Pot Again with Micro-Captives: Settlements Announced

On September 16, 2019, the Internal Revenue Service (“IRS“) announced that it would be mailing settlement offers for certain taxpayers under audit who participated in “abusive” micro-captive insurance transactions. The micro-captive transactions were listed as a transaction of interest by the IRS back in 2016. Section 2 of Notice 2016-66 described the transaction itself as…
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The Sale of a Business Part 4: Definitive Agreements

One of the more common engagements for our firm is to assist with business sales and acquisitions. This article is the third in a series of articles which will walk through and generally discuss the steps typically associated with the sale of a business. In Part 1, we discussed the breakdown of the business, the…
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