promoter Archives

Once Again, the “Tax Plan” Fails

Fiduciaries, Income Tax, Tax Controversy, Tax Court

Feb 22, 2022

On February 2, 2022, the Tax Court issued a memorandum opinion in the case of John M. Larson (“Larson”).[1] This case involves a dispute going back more than 20 years. Mr. Larson was an attorney and CPA. He and two other men, Robert A. Plaff and David Amir Makov, promoted a fraudulent tax shelter transaction…
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Injunctive Relief Hiding in Plain Sight? CIC Services, LLC v. IRS

Cases, District Court, Income Tax, Tax Controversy

Oct 1, 2021

So, we did not write on the first District Court case which was a loss for CIC Services, LLC (“CIC”) and Ryan, LLC(“Ryan”), the Plaintiffs. But, a Supreme Court decision gave the Plaintiffs another bite at the apple. This case involves Notice 2016-66 (“Notice”), the older-sibling notice to Notice 2017-10, in which micro-captive insurance transactions…
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Tag: promoter

Once Again, the “Tax Plan” Fails

Injunctive Relief Hiding in Plain Sight? CIC Services, LLC v. IRS

Directions

Creditor Rights to Beneficiary Interests in Irrevocable Trusts

Ivison – A Review on Amendments to Probated Claims

Prenuptial Agreements in Mississippi: Legal Technicalities and Practical Considerations