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Steven Robert Anderson's Legal Cases (2)

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Tax

Wandry v. Commissioner Of Internal Revenue Service

May 08, 2012

OUTCOME: Win

In an extremely important taxpayer victory, the United States Tax Court issued a memorandum opinion upholding the use of a defined value formula clause to fix the value of the donor’s gift for federal ... gift tax purposes. Wandry v. Commissioner, T.C. Memo 2012-88 (March 26, 2012). This type of formula clause is intended to prevent unanticipated gift tax from arising on a transfer, even if the IRS audits the transaction. The IRS withdrew its appeal of the Tax Court's Decision.

Tax

Intermountain Insurance Service of Vail, LLC v. Commissioner of the Internal Revenue,

Apr 25, 2012

OUTCOME: Win

The Supreme Court held IRS has just three years to bring a deficiency action against a taxpayer that reduces its tax liability by overstating basis instead of omitting gross income–not six years as the ... IRS argued. The Court's decision, published in United States v. Home Concrete & Supply, effectively overrules the D.C. Circuit’s decision in Intermountain Insurance Service of Vail, LLC v. Commissioner of the Internal Revenue, which had deferred to the IRS’s broad interpretation of the six-year statute of limitations for “omi[ssions] from gross income.”