Why a Tax Attorney’s Advice is Important: Case Study – Cavallaro

Estate Planning, Gift Tax, Business Succession, and the Ability to Rely on Advice of Counsel JD Supra Business Advisor recently published our case study on the Tax Court Opinion in the Cavallaro matters - a true rags to riches story involving taxation, and why a tax attorney's advice/representation is important....

Appeals Judicial Approach and Culture (AJAC) Project, Part II

Collection Due Process and Offers in Compromise In Part I of this series, we introduced the Appeals Judicial Approach and Culture (AJAC) Project and new guidelines for tax appeals. We also discussed the importance of having an independent IRS appeals process and noted that with limited exceptions, the government is...

Why a Tax Attorney’s Advice is Important: Estate Planning, Gift Tax, Business Succession, and the Ability to Rely on Advice by Counsel

Case of the Week: Cavallaro A recently published tax court opinion provides us with a fascinating case involving a rags to riches story of a tightly-knit hardworking family and the creation, merger and eventual sale of two related family companies. It hit our radar because of the impermissible tax position...

Your Frequent Flyer Miles May Be Taxable Income

For many years, banks have provided incentives to open a new bank account-30 years ago they handed out silverware and toasters, now they offer cash and frequent flyer miles. The IRS has for the most part ignored these incentives, but Citibank's overzealous interpretation of the tax code may have just...

IRS Appeals and the AJAC Project, Part I

Maintaining an Independent IRS Appeals process In an effort to demonstrate to taxpayers that IRS Appeals can be done in a fair and impartial manner by an independent appeals process, the IRS introduced the Appeals Judicial Approach and Culture (AJAC) Project which promotes a quasi-judicial approach in the handling of...

Special Issue: 2014 Tax Planning Roundup

What's Inside Planning: Year-End Investment Tax Planning Year-End Charitable Tax Planning Year-End Family Tax Planning Year-End Retirement Tax Planning Year-End Estate Tax Planning Year-End Business Tax Planning Tax Calendar Dear Client, Colleague, or Tax Enthusiast, Having just finished the extended 2013 tax filing season, we are aware of the very...