Montgomery v Commisioner of Internal Revenue, 17448-15
Apr 05, 2017OUTCOME: favorable settlement
T.Ct case involving small business substantiation and substantial underpayment penalties
New York, NY
Tax Lawyer at New York, NY
Practice Areas: Tax, Corporate & Incorporation, Estate Planning
OUTCOME: favorable settlement
T.Ct case involving small business substantiation and substantial underpayment penalties
OUTCOME: Settled on other grounds.
Expert testemony on tax questions relating to buyout of LP interest relating to application of Subchapter K partnership questions to underlying LP and tax aspects of allocations.
OUTCOME: Taxpayer victory on all issues.
Expert testemony relating to credit of NY non-resident taxation against CT DOR income tax, 'voluntary tax' issues and entity vs. aggregate theory of partnership taxation.