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Recent Articles & Treatises
- Registration now open for September 17, 2019 CPE Seminar, “IRC Sec. 199A: Wasn’t the Code to be Simplified?” August 26, 2019
- A Journey Through IRC Section 199A: Wasn’t the Code to be Simplified? July 25, 2019
- Tax News & Comment — August 2019 July 25, 2019
- Tax News & Comment – April 2017 March 13, 2017
- Tax News & Comment — May 2016 May 14, 2016
- FROM WASHINGTON & ALBANY — Current Election Probabilities; Tax Plans of Trump and Clinton May 13, 2016
- FROM FEDERAL AND NYS COURTS: Recent Developments & 2015 Decisions of Note May 13, 2016
- IRS & NYS DTF MATTERS: Recent Developments & 2015 Regs. & Rulings of Note May 13, 2016
- Creating and Maintaining Flexibility in Wills and Trusts May 13, 2016
- Escaping the Quandary Posed by Unreported Foreign Accounts May 13, 2016
- Like Kind Exchanges Alive and Well: An Update May 13, 2016
Most Popular
- September 17 CPE Breakfast Lecture in Old Westbury, New York -- "IRC Sec. 199A: Wasn't the Code to be Simplified?"
- Taxation of Foreign Nongrantor Trusts: Throwback Rule
- Use of Disclaimers in Pre and Post-Mortem Estate Planning
- Depreciation Recapture
- Defeating The Right of Election in EPTL § 5-1.1-A
- Executor and Trustee Commissions Under NY EPTL
- Lawyers
- Living Wills
- Gain, Loss and Depreciation Issues in Like Kind Exchange
- Tax and Legal Issues Arising In Connection With the Preparation of the Federal Gift Tax Return, Form 709 -- Treatise
Category Archives: Federal Tax Litigation
Private Letter Ruling Requests
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
Posted in Federal Income Tax, Federal Tax Litigation, IRS, IRS Rulings & Regulations
Tagged effect of letter rulings, effect of PLRs, income tax, irs, IRS letter rulings, Pre-submission conference, Private Letter Ruling Requests, Private Letter Rulings, Rev. Proc. 2015-1, Ruling Request Submission, User Fees for PLRs
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Tax Refund Litigation
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
Law Offices of David L. Silverman 
From Federal Courts, NYS Courts & Tax Tribunals — Recent Developments & 2014 Decisions of Note
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 →