Tax Law Updates

Featured Expert Legal Commentary

In re Quality Stores, Inc.: Sixth Circuit Excludes Some Severance Payments from FICA Tax

By H. Jacob Lager of Zuber Lawler & Del Duca

The Sixth Circuit has determined that some forms of severance payments are not taxable under FICA. In In re Quality Stores, Inc., No. 10-1563 (6th Cir. Oct. 6, 2012), the Court determined that payments made out of a company’s severance plans were SUB payments, which the Court concluded were not… More...

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TIFD III-E, Inc. v. United States: Second Circuit Rejects Debt Holder as Partner, Enforces § 6662 Penalties

TIFD III-E, Inc. v. United States  |  March 21, 2012

The Second Circuit recently found that partners whose interests are bound by overwhelmingly debt-like features are not partners for tax purposes. In TIFD III-E, Inc. v. United States, 666 F.3d 836 (2d. Cir. 2012), the Second Circuit rejected taxpayer’s argument that I.R.C. § 704(e)(1) broadened More...

Klauer v. Commissioner: Step Transaction Doctrine Does Not Apply to Multi-Step Bargain Sales to Charity

William R. Klauer v. Commissioner of Internal Revenue  |  July 19, 2010

The Tax Court has held that the step transaction doctrine did not apply to a series of bargain sales from a family-owned S Corp. to a charitable organization. As a result, the shareholders were entitled to charitable contribution deductions related to the sales. In William R. Klauer v. Commissioner More...

Holman v. CIR: Valuation of Gifted LLP Shares

Holman v. Commissioner of Internal Revenue  |  July 13, 2010

The Eighth Circuit U.S. Court of Appeals recently ordered that I.R.C. section 2703 could be applied to disregard transfer restrictions for valuations of gifts of shares in a family limited partnership (“FLP”). In Holman v. Commissioner of Internal Revenue, 601 F.3d 763 (8th Cir., 2010), the 8th More...

Steinhart v. Co. of Los Angeles: Transfer of Life Estate is a “Change in Ownership” of Real Property

Steinhart v. County of Los Angeles  |  March 10, 2010

The Supreme Court of California ruled that transfer of property to a revocable trust of which the transferor is sole beneficiary does not constitute a “change in ownership” triggering property reassessment under California law because the owner is still essentially the same person. However, if More...

U.S. v. Textron: IRS Is Entitled to Tax Accrual Work Papers

U.S. v. Textron Inc.  |  September 8, 2009

In a highly controversial split decision, the U.S. Court of Appeals for the First Circuit ruled that the work product privilege does not protect a company’s tax accrual work papers from IRS discovery. In U.S. v. Textron Inc., ____ F.3d ____, 2009 WL 2476475, No. 07-2631 (1st Cir. Aug. 13, 2009), More...

The “Amazon Tax” Upheld in New York, Enabling State Taxation of Web Sales LLC v. New York State Dept. of Taxation and Finance  |  April 8, 2009

In a case that has all major online retailers nervous, a Manhattan court upheld a new state tax law that requires many out of state retailers to collect state sales tax on purchases by New York residents in LLC v. New York State Dept. of Taxation and Finance, ___ N.Y.S. 2d ___, 2009 WL More...

Swallows Holding: 3rd Circuit Applies Chevron Deference to Uphold IRS Regulation

Swallows Holding, Ltd. V. Commissioner  |  November 17, 2008

The recent win for the IRS in Swallows Holding, Ltd. V. Commissioner, 515 F.3d 162 (3rd Cir. 2008), elucidates the ongoing debate over the appropriate standard for judicial review of Treasury regulations. In Swallows, the Third Circuit reversed a Tax Court decision and applied the highly More...

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Companies Mentioned

Tax Law

The following companies are mentioned in Tax Law Updates:

Swallows Holding, Inc.

Internal Revenue Service

The State of New York

New York State Department of Taxation and Finance LLC

Amazon Services, LLC

Textron Inc.

County of Los Angeles


Quality Stores, Inc.

Additional Resources

Tax Law