Caylor Land & Development Inc., Et Al. v. Commissioner, T.C. Memo. 2021-30
Mar 10, 2021OUTCOME: Rule 155 decision.
Captive insurance case involving IRC 831(b).
Scottsdale, AZ
Tax Lawyer at Scottsdale, AZ
Practice Areas: Tax, Tax Fraud & Tax Evasion
OUTCOME: Rule 155 decision.
Captive insurance case involving IRC 831(b).
OUTCOME: Rule 155 Decision
Estate tax and gift tax case involving family limited partnership case with testamentary charitable lead annuity trust.
OUTCOME: Win, no attorney fees from IRS.
Case involved taxpayer's defined benefit plan. Prior to trial, IRS conceded most of adjustment. Taxpayer requested attorney fees. Ultimately, court did not award attorney fees.
OUTCOME: Win
Midco transferee case involving interpretation of uniform fraudulent transfer act in Arizona.
OUTCOME: Loss, no penalties imposed
Case of first impression involving the application of IRC 62(a)(2)(C) and a judge's ability to claim above-the-line deductions as a fee-basis government official.
OUTCOME: Win
Material participation case involving yacht chartering business in the Caribbean. Court ruled taxpayers materially participated in their business, permitting them to deduct their losses against their ... ordinary income.
OUTCOME: Rule 155 Decision
Pertinent question is whether Evenchik obtained a qualified appraisal for a donation of stock.
OUTCOME: Rule 155 Decision
Valuation case involving approximately 2,500 acres in Lake Tahoe, CA.
OUTCOME: Win
Collection Due Process case involving proposed installment agreement or offer in compromise.
OUTCOME: Win
Case involving the allocation of interest expenses between investment interest and personal residence mortgage interest for deduction purposes.