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…
Specialists in Tax Litigation
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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 >>
Captive Insurance Audit Representation
Zerbe, Miller, Fingeret, Frank & Jadav is one of the nation’s most experienced law firms handling captive insurance audit defense and compliance. Representation of captive insurance company owners and service providers nationwide gives ZMFF&J a coordinated perspective on the issues and concerns regularly raised by the IRS in their examinations of taxpayers on this issue. …
