By Matt Spradling and Hale Stewart The State of California recently released FTB Notice 2023-02, which announced the Franchise Tax Board’s creation of a “resolution process” enabling certain taxpayers to resolve specific transactions that are possibly subject to the non-economic substance transaction (“NEST”) understatement penalties. Taxpayers must decide whether to voluntarily amend returns and unwind…
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ZMF is Victorious at the Courthouse on 179D Case
This week, the U.S. Tax Court, in a unanimous TC opinion, affirmed ZMF client’s entitlement to the 179D energy-efficient commercial building tax deduction in Johnson v. Commissioner. Not only was the deduction affirmed, but the Court agreed with every legal argument made by the ZMF team and rejected the IRS’s arguments in totality. The Court…
IRS Lacks Authority to Assess Section 6038(b) Penalties, Tax Court Rules By Oscar Carrillo, Senior Associate at Zerbe, Miller, Fingeret, Frank & Jadav LLP
The U.S. Tax Court recently held that the Internal Revenue Service (“IRS”) lacked statutory authority to assess Internal Revenue Code (“IRC”) Section 6038(b) penalties against an individual for failure to file Forms 5471, Information Return of U.S. Persons With Respect to Certain Foreign Corporations. The case has ramifications for any taxpayer that has been assessed…
US Tax Court finds ZMF Client wrongly denied $14M in deductions
Golf-Related Partnership Wrongly Denied $14M in Deductions A Texas limited partnership was wrongly denied the tax deductions for its for-profit activity, the U.S. Tax Court ruled Sept. 16. …continue reading >> View Opinion here >>
Ninth Circuit issues opinion protecting taxpayer rights on third party contacts
Ninth Circuit issues opinion protecting taxpayer rights on third party contacts – embracing arguments in amicus brief filed by Zerbe, Miller, Fingeret, Frank & Jadav. Continue reading… Read Amicus Brief here…
