Yesterday the Supreme Court held that the 40% gross valuation misstatement penalty under I.R.C. § 6662(h) is applicable in cases where the IRS determines that a partnership is a sham or lacks economic substance. United States v. Woods, No. 12-562 (U.S. Dec. 3,...
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Month: December 2013
Reminders for Year-End Charitable Donations
In addition to achieving philanthropic goals, many people make charitable donations at the end of the year in order to maximize income tax benefits. To make sure your charitable donation accomplishes both charitable and tax-savings benefits, here are few...
Tax Court finds former IRS agent liable for fraud penalty due to guilty plea in prior criminal proceeding
Yesterday the Tax Court issued an opinion in Senyszyn v. Commissioner, T.C. Memo. 2013-274, finding in favor of the IRS on summary judgment that a former revenue agent was liable for a fraud penalty and that the statute of limitations on assessment remained open....