The Art of an IRS APA Defense: Conservation Easements and Hewitt
Good tax attorneys will do whatever it ethically takes to win on behalf of their clients. Often, this means the attorney must not only have a good understanding of the substantive provisions at play,...
View ArticleIRS Notice 2007-83 Declared Unlawful Under the Administrative Procedure Act
The Administrative Procedure Act The Internal Revenue Code (the “Code”) contains over one hundred different civil penalties for various acts or failures to act. For example, Section 6707A requires...
View ArticleCourt Declares IRS Micro-Captive Notice 2016-66 Unlawful: What Taxpayers...
Introduction On May 17, 2021, the United States Supreme Court handed the IRS a significant loss when it concluded that CIC Services, LLC (“CIC”) could continue its lawsuit against the IRS for...
View ArticleMicro-Captive Insurance Arrangements Disclosure
CCA 202244010: What Constitutes Adequate Disclosure of Micro-Captive Insurance Arrangements Introduction: Micro-captive Insurance Arrangements Disclosure Micro-captive insurance arrangements are an...
View ArticleCorrection to APA Non-Compliance | IRS Issues Proposed Regulations for...
Freeman Law is, and for years has been heavily involved in advising on and defense of conservation easement charitable contributions authorized under section 170, Title 26 of the Internal Revenue Code....
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