When the IRS Disagrees With a Court, by Jasper Cummings

Jasper Cummings has published his article, “When the IRS Disagrees With a Court.” The summary is as follows:

In this report, Cummings investigates the IRS’s long-standing practice of issuing acquiescences and non-acquiescences to court decisions. He concludes that although a non-acquiescence to an unappealed adverse holding seems unfair to other

Continue reading

Replacing Charity: Why the IRS Denies Tax Exemption to 501(C)(3) Applicants by Terri Helge

Professor Terri Helge has made available for download her article, “Replacing Charity: Why the IRS Denies Tax Exemption to 501(C)(3) Applicants,” vol. 42, no. 5 (Sept./Oct. 2017). The Abstract is as follows:

New charitable organizations generally must file an application for exemption (Form 1023) and await approval from the Internal Revenue

Continue reading

Treasury Pulls Section 2704 Regs

The Treasury Department announced that it will pull several tax regulations identified as burdensome under President Donald Trump’s Executive Order 13789, including the proposed Sec. 2704 regulations that would limit valuation discounts for estate, gift, and generation-skipping transfer tax purposes (Second Report to the President on Identifying and Reducing Tax … Continue reading

Waiting for the Other Shoe, by Russell Willis

Russell Willis has published his article, Waiting for the Other Shoe., in Tax Notes. The Abstract is as follows:

Russell A. Willis III argues that the logic in the Tax Court’s Estate of Dieringer decision is flawed and that while the Ninth Circuit may reverse, the executor’s troubles may be

Continue reading