Exclusion of Employer-Provided Lodging Under IRC Section 119: The Vanicek and Moden Decision Introduction The case of Edward Vanicek, Deceased, and Sara Vanicek v. Commissioner of Internal Revenue,...
Tax Court Affirms Jurisdiction to Address Unreceived Refunds in Deficiency Determinations Introduction In the landmark case of Donald A. Naftel v. Commissioner of Internal Revenue (85 T.C. 527,...
Tax Court Establishes Jurisdiction to Address Nonreceipt of Refunds in Deficiency Calculations Introduction In the case of Donald A. Naftel v. Commissioner of Internal Revenue (85 T.C. 527, 1985),...
Sanctions Under the New Federal Rule 11: A Comprehensive Commentary Introduction The manifestation titled "SANCTIONS UNDER THE NEW FEDERAL RULE 11" was delivered by Judge William W. Schwarzer of the...
Rejecting Frivolous Altered Tax Returns: The Beard v. Commissioner Precedent Introduction The case of Robert D. Beard v. Commissioner of Internal Revenue, adjudicated by the United States Tax Court...
Adequate Notification Standards for Tolling Statute of Limitations in Tax Deficiency Cases Introduction In the case of Gerald H. Frieling, Jr. and Joan L. Frieling v. Commissioner of Internal Revenue...
Actual Receipt of Notice of Deficiency Validates Tax Court Jurisdiction Despite Incorrect Mailing Address Introduction The case of Richard L. Mulvania v. Commissioner of Internal Revenue, adjudicated...
Revisiting Functionality in Trademark Law: The Morton-Norwich Products Decision Introduction The case In re Morton-Norwich Products, Inc. (671 F.2d 1332) adjudicated by the United States Court of...
Addressing Deficiency Notices to APO Locations: Expanding Timely Filing Periods Under Section 6213(a) Introduction The case of Henry M. Brown and Barbara J. Brown v. Commissioner of Internal Revenue...
Centralized Pretrial Proceedings for Multi-Piece Rim Products Liability Litigation Introduction The case In re MULTI-PIECE RIM PRODUCTS LIABILITY LITIGATION (464 F. Supp. 969) represents a...
Exception to Res Judicata in Tax Deficiency Cases Involving Fraud: Breman v. Commissioner of Internal Revenue Introduction The case of M. William Breman and Sylvia G. Breman v. Commissioner of...
Jurisdiction Over Deceased Taxpayers: Edward J. Fehrs v. Commissioner of Internal Revenue Introduction Edward J. Fehrs, Deceased and Violette Fehrs brought forth a petition against the Commissioner...
Concurrent Use Agreements Mitigate Likelihood of Confusion: DuPont v. Horizon Industries Introduction The case of DuPont DeNemours & Co. v. Horizon Industries Corporation, adjudicated by the United...
Broadening the Scope of Fraud in Patent Proceedings: Norton v. Curtiss Introduction The case of Frederick H. Norton v. Lawrence E. Curtiss pertains to a patent interference dispute adjudicated by the...
Clarifying 'Last Known Address' for Deficiency Notices: McCormick v. Commissioner of Internal Revenue Introduction The case of Harvey L. McCormick v. Commissioner of Internal Revenue (55 T.C. 138)...
Golsan v. Commissioner: Disallowing Interest Deduction on Executive Special Life Insurance Policies Introduction In the landmark case of JACK E. GOLSEN AND SYLVIA H. GOLSEN, PETITIONERS v....
Substance Over Form: Disallowing Interest Deductions in Executive Special Life Insurance Loans Introduction The case of Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal Revenue (54...
Comprehensive Commentary on In re Plumbing Fixture Cases (298 F. Supp. 484) Disclaimer: This commentary is intended for informational purposes only and does not constitute legal advice. For legal...
Strict Substantiation Requirements for Entertainment Expenses Established in Sanford v. Commissioner Introduction The case of William F. Sanford v. Commissioner of Internal Revenue (50 T.C. 823)...
Comprehensive Analysis of the 1966 Amendments to Federal Civil and Criminal Procedure Rules for Admiralty and Maritime Claims Introduction On February 28, 1966, the Judicial Panel on Multidistrict...