On January 9, 2023, the United States Supreme Court will hear oral argument in In re Grand Jury, a landmark case regarding a Kostelanetz client’s assertion of the attorney-client privilege during a grand-jury investigation. The Kostelanetz client asserted the attorney-client privilege over communications between the client and the client’s prior lawyers in
Megan L. Brackney was quoted in an article in Tax Notes titled “IRS Appeals Training Materials on Reasonable Cause Worry Practitioners” on October 6, 2022. The article discusses the implications of recently disclosed training materials related to international information return penalties from the IRS Independent Office of Appeals. Practitioners are particularly concerned
Brian C. Wille was quoted in a recent Law360 article entitled “DC Circ. Urged To Undo Tax Court Tipster Denial In $60M Case,” published on April 25, 2022. The article discusses amici briefs filed in an appeal pending before the D.C. Circuit in which amici argued in favor of overturning
Kostelanetz & Fink served as counsel of record on behalf of the American College of Tax Counsel, which filed an amicus brief in the case of Alexandru Bittner v. United States on April 1, 2022. The College’s brief argued in support of the petition for a writ of certiorari seeking
CIC Services, LLC v. IRS, et al. No. 19-930, 593 U.S. ___, 2021 WL 1951782 (2021) Decided May 17, 2021 Yesterday, the Supreme Court issued a unanimous decision in CIC Services, LLC v. IRS, et al., holding that a suit under the Administrative Procedure Act (“APA”), 5 U.S.C. § 500
The Ninth Circuit Court of Appeals recently ruled in favor of a taxpayer subject to a non-willful civil penalty for failure to timely file an accurate Foreign Bank Account Report (FBAR), agreeing with a position advanced in a friend of the court brief written by Kostelanetz & Fink partners Caroline
By Claude M. Millman, with Russell A.S. Wirth New York Law Journal October 1, 2020 The New York State Court of Appeals is poised to hear oral argument in a case about the financing of a luxury, residential tower on Sutton Place in Manhattan—but some not-for-profits are saying that the outcome could
Caroline Rule, as Counsel to the New York Council of Defense Lawyers, authored an Amicus Curiae brief in the New York Court of Appeals in regards to the case People v. Neulander in which the prosecution is appealing the Appellate Division, Fourth Department’s grant of a new trial to Mr. Neulander on the grounds of juror
