IRS has issued final regs that reduce the amount determined under Code Sec. 956 for certain domestic corporations that own (or are treated as owning) stock in foreign corporations. Under the regs, neither an actual dividend to a corporate U.S. shareholder, nor such a shareholder's amount determined under Code Sec. 956, will result in additional…
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TC Determined That Responsible Person Penalty Invalid for Failure to Provide Pre-Assessment Determination
On remand from the Eleventh Circuit, the Tax Court has determined in Romano-Murphy, 152 TC No. 16, that IRS's assessment of the trust fund recovery penalty was invalid, rejecting the determination of the IRS Office of Appeals. Based on the Eleventh Circuit's finding that under Code Sec. 6672(b)(3)(B) and the Regs, IRS was required to issue a…
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The “See” Duction Did Not Work for Texas Restaurant Owners
According to DoJ, a Texas couple was convicted on May 23, 2019 of conspiracy and tax charges. Michael Herman and his wife, Cynthia Herman were convicted of conspiracy to defraud the United States by impeding the Internal Revenue Service (IRS) and of filing false individual income tax returns for tax years 2010 and 2011. The…
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Court Denies Dolphins Owner $33M Deduction For Land Gift To University of Michigan
According to Law360, a D.C. Circuit Court said real estate developer Stephen M. Ross and his partners could not deduct $33 million for land donated to the University of Michigan in 2003 and sustained a 40% penalty. In a unanimous decision, the three-judge panel said the U.S. Tax Court was right in finding that Ross' partnership…
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