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federal tax case law decisions
Tax Court Examines Tax Consequences to Taxpayer's Sale of Conservation Easement State Income Tax Credits in George H. Tempel, 136 T.C. No. 15 (2001)
In Tempel, the taxpayers sold a portion of their newly received transferable Colorado state income tax credits, i.e., in the aggregate sum of $260,000, that resulted from a donation of a conservation easement on approximately 54 acres of the petitioners' land in Colorado. In...
Eleventh Circuit Affirms Lower Court's Holding that Consulting Partner's Sale of Ernst & Young Interest Was Taxable in Year of Sale Despite Temporary Limitations on Economic Enjoyment
In U.S. v. Fort, 107 AFTR 2d ¶2011-739 (11th Cir. 4/19/2011) a three-judge panel of the Eleventh Circuit upheld a federal district court's (Northern District of Georgia) decision, granting the Department of Justice, Civil Tax Division, summary judgment on that issue that under the...
Tax Court Renders Favorable Decision on Rehabiliation Credits In Historic Boardwalk Hall, LLC. v. Commissioner
In Historic Boardwall Hall, LLC. V. Commissioner, 136 T.C. No. (2011) the Tax Court ruled that a LLC which was formed to facilitate a corporation's, i.e, Pitney Bowes, investment in the rehabilitation of an historic government building, East Hall, a National Historic Landmark property...
.Second Circuit Affirms District Court's Decision Rejecting Claim for Refund Based on Claimed Overvaluation of Employee Stock
In Gudmundsson v. U.S., 107 AFTR 2d 107 AFTR2d ¶2011-456 (2nd Cir. 2011) the Court of Appeals for the Second Circuit has affirmed a district court decision which dismissed the taxpayers’ claim for refund in tax based on an alleged overvaluation of stock one of the...
Reasonable Cause to Avoid Accuracy Related Penalty Based on Advice of Legal Counsel Rejected by Tax Court in Canal Corp. and Subsidiaries et al v. Commissioner, 135 T.C. No.9 (2010).
In Canal Corp., supra, the Tax Court recently held that a corporation's 1999 transfer of a wholly owned subsidiary to a joint venture was a disguised sale that required the company to include in capital gain the amount realized in the year of sale on its consolidated federal income tax return. An...