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Tag: Appellate Litigation

Kostelanetz Files Amicus Brief in U.S. Tax Court

Kostelanetz LLP has filed an amicus brief on behalf of the Center for Taxpayer Rights in support of petitioner Philip G. Groves in Groves v. Commissioner, T.C. No. 9974-22L, a case involving the IRS’s assessment of tax penalties. The petitioner is challenging penalty liability on the ground that the IRS

Navigating The Unsettled Listed Transaction Landscape

By Michael Waalkes The CPA Journal January 2024 Due to recent taxpayer-favorable court decisions requiring the Department of the Treasury to use formal notice-and-comment procedures under the Administrative Procedure Act (APA), the process by which the IRS publicly identifies listed transactions has undergone significant changes. It remains unclear whether these

IRS Doesn’t Have It Easy With Malta Pension Enforcement Efforts

By Caroline Ciraolo, Don Fort, and Ian Weinstock  Bloomberg Tax August 28, 2023 High-net-worth US taxpayers, working with professional advisers, have transferred assets into personal retirement plans established in Malta to limit and potentially eliminate tax on distributions. These so-called Malta pension plans rely on a specific interpretation of the