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…
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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…
NOT SO INDEPENDENT CAYLOR – THE NEWEST RULING ON “MICRO-CAPTIVES” FROM THE IRS
On Wednesday, March 10, the Tax Court issued its fourth case concerning “Microcaptive” insurance companies. In Caylor Land & Dev. v. Comm’r, the IRS continues its winning streak against captive arrangements. In the words of Judge Holmes, who authored the opinion as well as that of the seminal Avrahami case, “We will break no new…
ZMF SECURES APPRAISAL VICTORY FOR ELDERLY FAMILY
For residential and commercial property owners alike, the appraisal process can be as nebulous as it is unfamiliar. Many times, policyholders find themselves not only pitted against their own insurance carrier, but also the very contractors and appraisers who they retained to advocate on their behalf. Worse yet, appraisal can become a protracted process due…
I HAVE WATER DAMAGE IN MY HOME OR BUSINESS DUE TO A PIPE BREAK!! SO WHAT DO I DO NOW?!
As this article goes to print, Texas residents and business owners will have suffered hundreds of millions of dollars in property damage due to the recent Arctic outbreak that migrated to the Lone Star State. Homes and business throughout the southwest are facing consequences because water pipes are breaking. The effects of this meteorological phenomenon is…
