DPS Legal Counsel

We have all heard that old expression, "I've got some good news and some bad news. Which do you want to hear first?" The taxpayer in the case of Martin v. Commissioner, which was decided by the U.S. Tax Court and filed yesterday, was on the receiving end of the old...

There were a lot of important lessons to be gleaned from the U.S. Tax Court's decision in Scroggins v. Commissioner of Internal Revenue, which was filed yesterday. Two of the most helpful are these: (1) Just because a married couple files a joint tax return, it does...

If your tax-exempt organization has a calendar-year taxable year (i.e., its tax year ends on December 31 of each year), then yesterday was the deadline to file your yearly tax return (assuming you did not apply for a filing extension). The due date for tax-exempt...

In a recent posting, the Tax Court's decision in Pullins v. Commissioner of Internal Revenue was discussed. Last week, the Tax Court again ruled in favor of the taxpayer and held that Treasury Regulation 1.6015-5(b)(1) is invalid. The case in point on this go-round...

There was quite a stir in the media this past week surrounding so-called "social welfare" organizations that are exempt from federal income tax under Section 501(c)(4) of the Internal Revenue Code. Unlike the better-known 501(c)(3) organizations, which are prohibited...

Mr. Robinson taught classes at Temple University that were part of its Criminal Justice Training Program. Temple said that Mr. Robinson was an employee. Mr. Robinson disagreed and treated himself as an independent contractor on his income tax return. In effect, there...

The U.S. Tax Court decided an interesting case involving a Roth IRA last week. In effect, the Court's decision meant that the IRS couldn't have its cake and eat it, too. In Ohsman v. Commissioner of Internal Revenue, the taxpayer had established two separate...

Variable-rate demand municipal bonds backed by bank letters of credit are sometimes called "low floaters." Although low floaters have been common in municipal bond circles for a long time, the credit crisis that hit in late 2008 resulted in an even larger number of...

In an opinion of the United States Tax Court filed yesterday, May 5, 2011, the United States Tax Court continued to hold that relief for innocent spouses  under Section 6015(f) of the Internal Revenue Code is not subject to the 2-year deadline that the Internal...

Welcome to T for Taxes, T for Tennessee! It is my hope that you will find this blog to be a place where you will find interesting and provocative analysis and commentary on U.S. tax law and policy, as well as a discussion of significant recent developments in...