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2016 Articles

Could a departing shareholder’s continuation with the company as an employee or a consultant be treated as a “retained interest” under Section 2036 or 2701 of the tax code? By Hilary E. Wild November 2016 What if your client wants to remain an employee or an independent contractor of a corporation after gifting his stock in the corporation to his children?
The disappearance of the requirement that the Internal Revenue Service exhaust all reasonable collection efforts against the primary obligor By Benjamin Haskin September 2016 Recently, an increasing number of Memorandum Decisions in the United States Tax Court have summarily disposed of this requirement by stating that the existence and extent of transferee liability must be determined by state law, which often does not require the exhaustion of all reasonable collection efforts.
Estate of Stuller v. United States: Some lessons for horse-breeding farms By Colin Walsh March 2016 A close reading of this case uncovers some important insight regarding the need to consult with experts and who qualifies as such.
IRC Section 280(e)’s impact on Illinois medical marijuana By James Creech June 2016 While the Illinois medical marijuana program faces many obstacles at the state level, its largest challenge may be the Internal Revenue code.
Letter from the Chair By Nancy Franks-Straus June 2016 A message from Chair Nancy Franks-Straus.
Letter from the editor By Paul Fagyal November 2016 An introduction to the issue from Editor Paul Fagyal.
Letter from the editor By James Creech September 2016 A message from Editor James Creech.
Letter from the editor By James Creech April 2016 A message from Editor James Creech.
Notes from the Chair By Nancy Franks-Straus March 2016 A message from Section Chair Nancy Franks Straus.
President Trump and the existential crisis of 7443 By James Creech June 2016 What happens when the President has a stake in litigation where he holds the power to remove the judge?
Proposed IRS regulations may eliminate long-standing discounts for family-owned businesses By Bruce A. Johnson November 2016 The Internal Revenue Service released proposed regulations on August 2, 2016 that would modify and expand Internal Revenue Code 2704 (IRC 2704) impacting the valuation of privately-held, minority interests that are controlled by the same family.
Tax scams hit home By Kathryn Garlow March 2016 Tips and suggestions to help your client avoid scams.
What is a coordinated appeals issue? By James Creech September 2016 Known internally as Appeals Coordinated Issues, or ACI for short, they can be a peek into what the IRS considers hot topics in tax or potential areas for abuse.
The worst call I have ever had with the IRS… and how the agent redeemed himself By James Creech April 2016 The author recalls a recent conversation with an agent of the IRS.