In a recent article, my colleague Gray Edmondson covered the recent Supreme Court case, Loper Bright[1], and the demise of the Chevron Doctrine.[2] The Loper Bright case was handed down by the Supreme Court on June 28, 2024. As Gray explains in his article, the Chevron case has to do with determining the validity of…
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In a recent Tax Court case, the Court determined that the 90-day deadline for filing a petition for redetermination of employment status is not jurisdictional and thus does not prevent the Court from hearing the case.[1] While an all-too-familiar statute pertaining to the jurisdiction of the Tax Court to hear a matter has generally been…
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If you started a business organized as a C corporation, you may be able to avoid some, and possibly all, tax liability when you sell the stock of the C corporation. As previously written upon by Gray Edmondson,[1] Section 1202 of the Internal Revenue Code (“Code”) provides for the exclusion of gain on Qualified Small…
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On March 25, 2024, the IRS issued Prop. Reg. Section 1.6011-15[1], which designates certain transactions involving charitable remainder annuity trusts (“CRATs”) in tandem with single premium immediate annuity (“SPIA”) products as listed transactions[2]. Last year, I wrote an article in which the Tax Court decided against a taxpayer couple who undertook this exact transaction.[3] Now,…
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On February 8, 2024, the Mississippi Supreme Court issued its opinion[1] regarding an issue of first impression regarding Mississippi’s Principal and Income Act of 2013 (the “Act”).[2] As a worthwhile note, the Court noted that this is an issue of first impression and acknowledged as well as appeared to oblige the parties so as to…
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Every year, the Internal Revenue Service (“IRS”) releases its “Dirty Dozen.” The Dirty Dozen, as written previously about by my colleague, Devin Mills,[1] is a list of twelve prevalent scams the IRS bodes taxpayers to be weary of during tax season, as they “put taxpayers, businesses, and the tax professional community at risk of losing…
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What is the CTA? Congress passed the Corporate Transparency Act (“CTA”) at the end of 2020 as part of a larger bill referred to as the Anti-Money Laundering Act, which in turn was part of the National Defense Authorization Act of 2021. It was signed into law by President Biden on January 1, 2021. The…
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The late Justice Antonin Scalia once remarked that federal judges should have a rubber stamp that’s says “Stupid But Constitutional.” The Constitution, in other words, does not allow judges to strike down a law merely because it is burdensome, foolish, or offensive. Yet the inverse is also true – the wisdom of a policy is…
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Split dollar life insurance arrangements can take on a number of forms, and the exact structure of the arrangement determines the tax consequences, which can become complicated quickly. In a recent case out of the District Court of Ohio, the court held that an insurance arrangement between a single member C corporation, Peter E. McGowan…
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Monetized Installment Sales, as previously written upon by Gray Edmondson,[1] have been subject to increased scrutiny by the IRS in recent years, making its “Dirty Dozen” list in each of the last three years.[2] The IRS remains on the offensive in scrutinizing such transactions, issuing proposed regulation under Internal Revenue Code Section 6011 in August…
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