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How Big Is Sixth’s Circuit’s Attack On IRS Substance Over Form Rule?

by admin | Feb 28, 2017 | Tax

Originally published on Forbes.com. Summa Holdings, a Sixth Circuit opinion written by Judge Jeffrey Sutton is causing a bit of a stir in the tax world. The gimmick that the Berenson family’s attorneys were defending, using a corporate tax break for export...

Conservative Judge Okays Huge Roth IRA Tax Shelter, Slams IRS Substance Over Form

by admin | Feb 20, 2017 | Tax

Originally published on Forbes.com. Judge Jeffrey Sutton is confirming his status as “the intellectual engine behind a conservative movement of the jurisprudence of the Sixth Circuit” in Summa Holdings vs CIR. The opinion limits the use by the IRS of the...

Match Group CEO Wins Tax Case By Arguing His Heart Was In Texas With His Dog

by admin | Feb 19, 2017 | Tax

Originally published on Forbes.com. Greg Blatt, Chairman and CEO of Match Group did quite well in the New York Division of Tax Appeals early this month. The Division of Taxation was looking for over $400,000 in state and city income tax for the years 2009 and 2010...

Target Brands Unit Cannot Entirely Avoid Colorado Income Tax

by admin | Feb 16, 2017 | Tax

Originally published on Forbes.com. Saying it is all about the brand to minimize state income taxes, is probably the main theme of Target Brands Inc v Brohl, which was recently decided in the District Court for the City and County of Denver. Target Brands Inc, where...

City Plays Grinch When Ellen DeGeneres Helps Single Mother

by admin | Feb 12, 2017 | Tax

Originally published on Forbes.com. It looks like RF, who was found guilty of a first-class misdemeanor as an indirect result of her appearance on the Ellen DeGeneres Show, may have caught just a bit of a break thanks to a decision of the Court of Appeals of the Ohio...

Clergy Housing Tax Break Seen As Unconstitutional

by admin | Feb 10, 2017 | Tax

Originally published on Forbes.com. Professor Adam Chodorow has produced a very timely article (pdf downoland) on the constitutionality of the parsonage exemption. The parsonage exemption (Code Section 107) allows “ministers of the gospel” to exclude the...