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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...
Every individual wants to get the most deductions and credits from their tax returns. These tax issues can save individuals a substantial amount of money and, in some cases, can result in the individual receiving a healthy check from the IRS. However, despite the...
On October 2, 2012, the Court of Appeal issued its decision in Gillette v. Franchise Tax Board. The case revolved around the issue of whether taxpayers could elect to utilize the apportionment formula contained in the Multistate Tax Compact instead of the mandatory...
A California man is facing federal criminal prosecution currently, having been charged with five counts of tax evasion. In making the tax crimes allegations, prosecutors allege that the man failed to report over $1 million in income over a five year period. It is...
On August 9, 2012, the California Court of Appeal "on its own motion and for good cause" vacated its decision and opinion issued on July 24, 2012 in Gillette v. Franchise Tax Board, and ordered a rehearing. The Franchise Tax Board (FTB) dismissed the taxpayer's...
There are circumstances that arise which may put an individual in a financial hole with the IRS. This can often lead to a California resident owing back taxes to the state and federal government, which can amass quickly if left unresolved. Although the fear of an IRS...
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...
Many homeowners are currently enjoying some much needed relief on the principal of their mortgage loans. Although this relief has assisted many in either selling their home through a short sale or making existing monthly payments more affordable, a tax issue may be on...
The Recorder, a California legal publication, reports on oral argument in a Ninth Circuit case involving the act of production doctrine. Under this doctrine, a person can invoke his Fifth Amendment rights against the production of documents only where the very act of...
Coming up this month:Amy Halloran will present "Tax Aspects of Estate Planning" for Young Tax Lawyers on September 20, 2012Ms. Halloran will discuss the some of the most costly mistakes in estate planning when income tax aspects are ignored and how a good estate plan...
