In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its previous name of “Dukes”), making findings with regards to reasonable cause, valuation of personal goodwill, correct reporting of capital
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Tax Court Finds that SECA Limited Partner Exception Requires ‘Functional Analysis Test’
Co-author Caleb O’Donnell*
A recent U.S. Tax Court decision provides clarity to what the Internal Revenue Service (“IRS”) considers a limited partner for purposes of the ‘limited partner exception’ to the Self-Employment Contributions Act (“SECA”) tax under Code Sections[1] 1402(a)(3) and 1402(a)(13) (the “Limited Partner Exception”). The Tax Court held in Soroban Capital Partners…
Joshua Smeltzer Quoted by Law360 on FTX’s $24B Tax Bill
FTX is embroiled in a $24 billion tax dispute with the Internal Revenue Service (IRS) in its bankruptcy case. The IRS claims FTX owes this amount in unpaid taxes, but FTX says the claim has “no relation to reality” (Law360, 2023). An estimation hearing has been ordered by the bankruptcy judge to determine the validity…
Identity Theft and the IRS – what can you do?
Everyone knows that identity theft is a big problem in the United States. In recent testimony before Congress the subject of stolen identity refunds was front and center.
The IRS estimates that more than 641,690 incidents of tax-related identity thefts have occurred through September of 2012. This is an exponential increase from 2008 which only…
Whistleblower Award – How to get the IRS to pay you!
Earlier this year the IRS awarded Bradley Birkenfeld a record award of $104,000,000. The Wall Street Journal has a great article on the award.
In order to recieve an award you have to provide the IRS with specific and credible information. This information then has to result in the collection of money from the “taxpayer.”
The…