Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United States. The appellate court had previously concluded that the taxpayer was not entitled to a claimed capital loss from a transaction involving the acquisition of distressed debt via a partnership because the partnership was a “sham” that should be disregarded for federal tax purposes. The taxpayer's petition for rehearing, along with two amicus briefs, raised the specter that the Fifth Circuit's opinion would require taxpayers to have a non-tax ...
At Chamberlain, we are very proud of our colleagues’ efforts on behalf of pro bono clients. Two of our attorneys, Juan Vasquez, Jr. and Jaime Vasquez of the firm's Houston office, along with Peter Lowy of Shell Oil Company, recently argued a pro bono case in front of the Fifth Circuit Court of Appeals in Terrell v. Comm’r.
The Fifth Circuit reversed and remanded a U.S. Tax Court ruling which dismissed the taxpayer’s petition for lack of jurisdiction because she filed her petition more than 90 days after the IRS sent her a Notice of Final Determination. Noting that the IRS was on ...