On October 9, 2012, the U.S. Supreme Court denied, without comment, Scholastic Book Club's petition for certiorari, declining to hear an appeal regarding Connecticut's taxation of classroom catalog sales of books to students.Earlier this year, the Connecticut Supreme...
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Tax Controversy
Tax Court Lacks Jurisdiction to Review IRS’s Refusal to Pursue Whistleblower’s Claim
In a case of first impression, the United States Tax Court held that it lacked jurisdiction under Internal Revenue Code (IRC) Section 7623(b) to review the IRS's refusal to pursue a whistleblower's claim. Cohen v. Commissioner, 139 T.C. No. 12 (Oct. 9, 2012)In this...
Federal Judge Shoots Down Hundreds of Millions in Tax Losses claimed by Broadcom Co-Founder
In Broadwood Investment Fund LLC v. United States, No. 08-0295 (C.D. CA Sept. 21, 2012), a California federal district court judge rejected, on summary judgment, a bid by Broadcom co-founder Henry Nicholas, III, to claim hundreds of millions in tax losses from a tax...
Mailbox Rule Does Not Apply To All Fed Ex Deliveries
Not rain, nor sleet, nor snow will stop the U.S. Postal Service from delivering your Tax Court Petition, but try to save a few bucks by using Federal Express' "Express Saver Third Business Day" and your petition is not considered "mailed" according to the U.S. Tax...
IRS Audits Lead to Fraud Referrals as the IRS Seeks to Collect Revenue
Although most taxpayers are not deliberately trying to commit a crime by filing a "creative" tax return, or simply not filing a tax return, the reality is that such action, or inaction, can in fact lead to a criminal or civil fraud investigation. Although the statute...
IRS Announces That Per Capita Payments From Settlement of Tribal Trust Cases Are Not Taxable
The United States entered into agreements earlier this year with certain federally recognized Indian tribes to settle long-running lawsuits in which the tribes accused the Interior Department and the Treasury Department of mismanaging the monetary assets and natural...
And You Thought Taxes Were Boring…
This week, the Court of Appeals in the state of New York has been asked to determine whether or not revenue earned by strip clubs from admission fees and lap dances are subject to state sales tax or whether such income falls under an exemption relating to dramatic or...
Good News for Taxpayers Living Abroad with Unfiled Tax Returns or FBAR Reports
Beginning September 1st, some taxpayers living abroad who have not filed tax returns will get help from the IRS, if little or no back taxes are due. This is a great relief to taxpayers who have lived overseas and have failed to file timely tax returns or Reports of...
Court Orders Production of Foreign Bank Account Records Despite Claim for Fifth Amendment Privilege
On August 27th the Seventh Circuit decided In Re: Special February 2011-1 Grand Jury Subpoena Dated September 12, 2011. The Court held that the required records doctrine requires a taxpayer asserting a Fifth Amendment privilege to produce the documents required to be...
California Couple Receives Prison Sentence in Offshore Account Tax Evasion Case
Sean and Nadia Roberts of Tehachapi, California, pled guilty before the Eastern District of California to a criminal information charging them with filing a false tax return under Internal Revenue Code § 7206(1). The charge is related to an undisclosed Swiss bank...
