The IRS has recently announced a compliance campaign intended to address “the attempted deferral of contingent or court-awarded attorney fees by cash-method attorneys/law firms (taxpayers) who direct that such fees be paid to a third-party instead of the taxpayer.”[1] The IRS is concerned that plaintiff’s attorneys are deferring payment of income tax on legal fees…
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President Franklin Delanor Rosevelt signed the Social Security Act on August 14, 1935, with regular monthly benefits starting in January of 1940.[1] Since then, the Social Security system has formed the foundation of the retirement system for most Americans. However, Social Security covers much more than just retirement income, as it provides benefits for surviving…
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As of the release of iOS 15.2, December 13, 2021, Apple released a new feature for its users, “Legacy Contacts”.[1] Historically, estate fiduciaries could receive this information with a court order, but the new process is designed to minimize the expense of time and money associated with getting access to a decedent’s account information. So,…
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The Mississippi Vulnerable Persons Act of 1986 (“MVPA”) was passed by the Mississippi Legislature in 1986 to provide protection for vulnerable persons in Mississippi who are abused, neglected, or exploited.[1] In addition to providing the penalties associated with abusing, neglecting, and exploiting a vulnerable individual, the MVPA requires that individuals report instances of known or…
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As tax planning practitioners, we do not typically see issues we deal with daily become the subject of cases before the United States Supreme Court. This term, we had the Connelly[1] case involving estate tax valuation of a decedent’s stock in a corporation funding a redemption buy-sell with corporate-owned insurance. Shortly thereafter, the Supreme Court…
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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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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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The recent opinion from the United States District Court, Eastern District of Tennessee, continues the saga of the case of CIC Services, LLC (“CIC”) and has implications for taxpayers seeking to recover attorneys’ fees under the Equal Access to Justice Act (“EAJA”) and for its broader reflections on governmental fairness, particularly those looking to challenge…
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Clients often ask where they should form a new legal entity to obtain the best creditor protection. Blogs, marketing materials, and similar items often tout one or another jurisdiction as the best place to form legal entities. It certainly is the case that state laws differ. One of those areas is in “charging order” protections…
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Every year the IRS publishes its list of the top tax scams that taxpayers should be aware of, known as the Dirty Dozen. I discussed the IRS’s 2021 Dirty Dozen list in a prior web article,[1] and the IRS has recently released its 2023 Dirty Dozen list.[2] Several of these scams are designed to steal…
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