While states often lag behind the IRS in enforcement of IRS priority issues, the California Franchise Tax Board (FTB) has begun to show an interest in looking deeper into captives owned by California residents. While the FTB has made no formal pronouncements about its intention (unlike the IRS, which has classified certain microcaptive transactions as…
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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…
IRS Needs to Improve Data Controls for Some Award Determinations
GAO publicly releases report on the IRS Whistleblower program, GAO-18-698. …continue reading >>
TIGTA report on IRS whistleblower program
The Whistleblower Program Helps Identify Tax Noncompliance; However, Improvements Are Needed to Ensure That Claims Are Processed Appropriately and Expeditiously …continue reading >>