Tax Law News and Insights

Recent revelations involving documents found to be backdated by the IRS in the case of Lakepoint Land II, LLC v. Commissioner resulted in the Tax Court imposing sanctions on the IRS. Further inquiries ensued as to whether the IRS also proffered backdated penalty documents in other similar cases, hinting at a troubling...

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On August 4, 2023, the IRS published proposed regulations that, if finalized, would identify monetized installment sale transactions as a listed transaction. Sellers, intermediaries and other involved parties would be required to report such transactions to the IRS. These proposed regulations come nearly two years after the IRS for the...

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On June 20, 2023, the Court of Federal Claims denied summary judgment to the taxpayer in Alta Wind I Owner-Lessor C, et al. v. United States ("Alta Wind (2023)"),1 the latest episode in an ongoing multifaceted dispute over the calculation of the Section 1603 grant. While the Section 1603 grant expired over a...

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