Don’t Be SOL Because of the SOL

The federal government shutdown is stretching into week four, and there is no end in sight. The shutdown has affected all federal agencies and courts, including the United States Tax Court. One question raised by the shutdown is what effect does it have on Tax Court filing deadlines? The question is important because statutory filing…
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The Fight Against Secret Tax Law

One of the most difficult aspects of state and local tax practice is the lack of publicly available guidance addressing a client’s situation. One potentially rich source of guidance are orders issued by administrative tribunals in taxpayer appeals. These orders are similar in form and function to judicial opinions. Unlike judicial opinions, however, these orders…
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Melasky: When the Levy Breaks

Last week the Tax Court handed down its opinion in Melasky v. Comm’r, 151 T.C. 9 (Oct. 10, 2018). The important issue in Melasky relates to the application of the proceeds of a levy. Four days prior to the date the levy was made, the taxpayer hand-delivered a check to the IRS and properly designated…
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The Intersection of the TCJA and the Mississippi Income Tax

The Tax Cuts and Jobs Act (“TCJA”) is arguably the most significant tax legislation passed by Congress since last revision of the Internal Revenue Code in 1986. The legislation fundamentally altered the Code by reducing or eliminating many longstanding, popular deductions and credits while expanding others and creating new ones. Much has been written about…
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199A Proposed Regulations: Clarifying Scope Of Specified Services Trade or Business Under Section 199A

The Internal Revenue Service (“IRS”) recently issued proposed regulations on the new deduction for qualified business income (“QBI”) under new Code section 199A. Among other things, the proposed regulations address the hotly debated interpretive issue regarding the term “specified service trade or business” (“SSTB”). SSTB is a key term under section 199A because, if an…
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