Category Archives: Federal Tax Litigation

From Federal Courts, NYS Courts & Tax Tribunals — Recent Developments & 2014 Decisions of Note

Posted on February 19, 2015 by David L. Silverman, J.D., LL.M. (Taxation)

I.     Disputes Involving Sales of Assets to Grantor Trusts Reach the Tax Court In Estate of Woelbing v. Com’r, Docket No. 30261-13, filed on December 26, 2013, the IRS made several arguments seeking to negate the tax benefit sales of … Continue reading →

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Private Letter Ruling Requests

Posted on February 18, 2015 by David L. Silverman, J.D., LL.M. (Taxation)

I. Introduction Private letter rulings are in the nature of “advisory” rulings by the IRS concerning the tax implication of income or estate transactions contemplated by taxpayers. As stated in Rev. Proc. 2015-1, the IRS generally issues a letter ruling … Continue reading →

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Tax Refund Litigation

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

To commence a lawsuit against the I.R.S. seeking the refund of federal taxes erroneously or illegally assessed or collected, a taxpayer must select a court of proper jurisdiction.  Jurisdiction to hear federal tax cases is conferred by federal statute, and … Continue reading →

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