Looking for opportunities to reduce tax liability is common. There is nothing wrong with seeking to reduce tax exposure. The late Judge Learned Hand is famous for a commonly quoted opinion from the Second Circuit Court of Appeals, saying: “Anyone may arrange his affairs so that his taxes shall be as low as possible; he…
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In a significant taxpayer-favorable decision[1], the Fourth Circuit recently held that erroneous refunds of underpayment interest may constitute “unpaid tax” eligible for equitable innocent spouse relief under Section 6015(f) of the Internal Revenue Code (“Code”). Section 6015(f) provides an avenue for relief (at the IRS’s discretion) for unpaid tax or a deficiency when it would…
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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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