Allocation of Income Regs Valid Under Chevron, State Farm Says USTC. See, 3M Company and Subsidiaries, (2/9/2023) 160 T.C. No. 3, where the Tax Court upheld the proposition that various regulations under Code Sec. 482 are valid under the two Supreme Court tests for...
Tax attorney Chaya Kundra will co-chair and speaker at the following upcoming events on employment tax updates. Name of event: Employment Tax Update Date: February 10, 2023 Time: 3pm to 4pm Name of event: Employment Tax Issues & Opportunities Impacting M&A...
Supreme Court Hears Arguments on Alternative Attorney-Client Privilege Test. Oral arguments before US Supreme Court on 1/9/23 involving subpoenas of recorded communications comprised of both of tax and legal advice. In re Grand Jury, concerned unnamed law firm...
IRC 2056: Estate granted 120-day extension to make Sec. 2056(b)(7) QTIP election with respect to marital trust where taxpayer acted reasonably and in good faith and granting relief would not prejudice Gov.'s interests. (PLR 202249006) IRC 6330 (CDPH & no face to...
