In addition to the discussion of the recently proposed U.K. criminal tax legislation, this month’s issue features articles regarding the Tenth Circuit Court decision in McNeill v. United States
discussing a managing partner’s right to raise a partner-level good faith and reasonable cause defense to penalties, the District Court’s decision in Interior Glass
, which upheld the constitutionality of section 6707A, the Second Circuit’s decision in United States v. Greenfield
, concluding that an IRS summons violated taxpayer’s Fifth Amendment protections against self-incrimination, the Federal Circuit’s decision in Nacchio v. United States
which held that a forfeiture payment could not be deducted under section 162, the IRS’ recent announcement to change the CAP Program and Revenue Procedure 2016-45 that announced that the IRS will issue letter rulings on two spinoff-related areas under section 355.
View full memo, Focus on Tax Controversy and Litigation