Tag: adjustment

Supervisory Approval and the Assertion of Penalties: Palmwood Holdings, LLC v. Comm’r

Charitable Giving, Income Tax, Tax, Tax Controversy, Tax Court

In Palmwood Holdings, LLC v. Comm’r, the United States Tax Court granted partial summary judgment in favor of the IRS, holding that the Service satisfied the supervisory approval requirement of section 6751(b) with respect to a civil fraud penalty first asserted in the IRS’ answer. The decision reinforces a growing body of Tax Court precedent…
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Closely-Held Family Partnerships: New Reporting Obligations

Compliance, Estate Planning, Income Tax, Regulatory, Tax, Tax Controversy

Treasury recently finalized regulations imposing significant reporting obligations on persons involved in what the regulations describe as “related party basis adjustment transactions.” These regulations designate such transactions as “transactions of interest,” a form of reportable transactions.[1] Reporting obligations can apply to transactions completed prior to the date of these regulations and also may extend many,…
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