Rowan Companies, LLC v. United States
|
Southern District of Texas
|
Whether IRS must pay refund approved by Joint Committee on Taxation
|
Pending
|
Robert C. Morris
Stephen A. Kuntz
Richard L. Hunn
|
Ensco International Inc. v. United States
|
Southern District of Texas
|
Whether IRS must pay refund agreed to during IRS examination as part of Compliance Assurance Process
|
Pending
|
Robert C. Morris
Stephen A. Kuntz
Richard L. Hunn
|
Suo Bin Chen and Yan Jiang v. Commissioner
|
Tax Court
|
Collection due process rights, underlying tax liability, and penalties
|
Pending
|
Robert C. Morris
Richard L. Hunn
|
Polycom, LLC v. United States
|
Court of Federal Claims
|
Entitlement to alternative minimum tax refundable credit
|
Government. conceded
|
Robert C. Morris
Stephen A. Kuntz
Richard L. Hunn
|
Diamond Offshore Drilling, Inc. v. United States
|
Southern District of Texas
|
Entitlement to foreign tax credit and statute of limitation issues
|
Settled
|
Robert C. Morris
Stephen A. Kuntz
Richard L. Hunn
|
Roseta v. Commissioner
|
Tax Court
|
Whether the taxpayer received a taxable distribution
|
Government conceded
|
Robert C. Morris |
Noble Drilling Corporation v.
United States
|
Southern District of Texas
|
Entitlement to foreign tax credit for foreign taxes paid to Mexico and other foreign jurisdictions
|
Settled
|
Robert C. Morris
Stephen A. Kuntz
|
HP Inc. v. United States
|
Court of Federal Claims
|
Overpayment interest
|
Government conceded
|
Robert C. Morris
Richard L. Hunn
|
Delek US Holdings, Inc. v. United States of America
32 F. 4th 495 (6th Cir. 2022)
|
Sixth Circuit Court of Appeals
|
Income tax treatment of Section 6426 alcohol and biodiesel mixture credits
|
Judgment affirmed
|
Robert C. Morris |
JSB Montana, Inc. v. Commissioner and 12 related cases
|
Tax Court
|
Whether IRS Appeals could consider consolidated or “test case” settlement of related Collection Due Process cases
|
Pending
|
Jasper G. Taylor III
Richard L. Hunn
|
Delek US Holdings, Inc. v. United States of America
127 AFTR 2d 2021-641 (M.D. Tenn. 2021)
|
Middle District of Tennessee
|
Income tax treatment of Section 6426 alcohol and biodiesel mixture credits
|
Judgment for government
|
Robert C. Morris |
Lorance & Thompson, A Professional Corporation v. Commissioner
|
Tax Court
|
Excise taxes and failure-to-file and failure-to-pay penalties with respect to a terminated defined benefit pension plan
|
Government conceded two of three years; settled third year
|
Robert C. Morris
Richard L. Hunn
|
Baker Hughes Incorporated v. United States of America
943 F.3d 255 (5th Cir. 2019)
|
Fifth Circuit Court of Appeals
|
Whether payment to a foreign subsidiary qualifies for either a bad debt deduction or ordinary and necessary business expense
|
Judgment affirmed
|
Reagan M. Brown
Robert C. Morris
Stephen A. Kuntz
|
United States v. Rao Desu
|
District of New Jersey
|
Conspiracy of tax evasion for cash skim from two independently owned pharmacies.
|
Judgment for government
|
Mayling C. Blanco
|
The Diversified Group Incorporated, et al. v. Commissioner
|
Tax Court
|
In Collection Due Process cases, whether taxpayers may dispute liability for penalties under pre-2004 section 6707; penalty approval under section 6751(b)
|
Pending
|
Jasper G. Taylor III
Richard L. Hunn
|
Estate of Abraham Damast, Deceased, Gary Damast, Adrienne D. Wilson, Executors and Donald A. Damast, Administrator CTA v. Commissioner
|
Tax Court
|
Estate and gift taxes in connection with sale of receivables from split dollar life insurance transactions; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
Jacques E. Bouchez and Cristina C. Bouchez v. United States
|
Southern District of Texas
|
Whether revisions to ending inventory and cost of goods sold were an unauthorized accounting method change
|
Government conceded legal issue; settled calculation issues
|
Robert C. Morris
Richard L. Hunn
Stephen A. Kuntz
|
Individual who was the co-owner of a pharmacy and was the target of a federal criminal tax grand jury investigation
|
U.S. Attorney’s Office for the District of New Jersey
|
Tax evasion resulting from multi-year cash skim from pharmacy business
|
Declination of charges
|
Mayling C. Blanco |
Nickowski v. Commissioner
|
Tax Court
|
Whether amounts received by the taxpayer were taxable as divided income
|
Settled
|
Robert C. Morris
Richard L. Hunn
|
1 Your Front Desk Service, Inc. v. Commissioner
|
Tax Court
|
Whether the IRS could increase the amount of sales reported by the company, plus miscellaneous other issues
|
Settled
|
Robert C. Morris
Richard L. Hunn
|
The Diversified Group Incorporated and James Haber v. United States
841 F.3d 975 (Fed. Cir. 2016)
|
Federal Circuit Court of Appeals
|
Whether pre-2004 section 6707 penalties are divisible taxes and thus subject to Court of Federal Claims’ jurisdiction
|
Judgment affirmed
|
Jasper G. Taylor III
Richard L. Hunn
|
James Haber v. United States
823 F.3d 746 (2d Cir. 2016)
|
Second Circuit Court of Appeals
|
Validity of IRS summons issued while a Justice Department referral was in effect; whether summons was in aid of collection
|
Judgment affirmed
|
Jasper G. Taylor III
Richard L. Hunn
|
BRC Operating Company v. Commissioner of Internal Revenue
|
Tax Court
|
Validity of Treasury Regulations extending the economic performance requirement to cost of goods sold; accuracy-related penalties and penalty approval under section 6751(b); whether taxpayer may claim deduction for accrued expenditures
|
Trial pending on deduction issues; IRS conceded penalty issue as part of settlement
|
Robert C. Morris
Charles W. Hall
Richard L. Hunn
|
Bluescape Resources Company v. Commissioner of Internal Revenue
|
Tax Court
|
(1) Validity of Treasury Regulations extending the economic performance requirement to cost of goods sold, (2) worthlessness deductions for leases; (3) availability of mark-to-market method of accounting; (4) accuracy-related penalties, (5) penalty approval under section 6751(b); and (6) whether taxpayer may claim deduction for accrued expenditures
|
Trial pending on deduction issues; settled worthlessness, mark-to-market, and penalty issues
|
Robert C. Morris
Charles W. Hall
Richard L. Hunn
|
Baker Hughes Incorporated v. United States of America
121 AFTR 2d 2018-2113 (S.D. Tex. 2018)
|
Southern District of Texas
|
Whether payment to a foreign subsidiary qualifies for either a bad debt deduction or ordinary and necessary business expense
|
Judgment for government
|
Reagan M. Brown
Robert C. Morris
Stephen A. Kuntz
Richard L. Hunn
|
ADAMS Challenge (UK) Limited v. Commissioner of Internal Revenue
154 T.C. No. 3 (2020)
|
Tax Court
|
Whether a foreign company (1) has income connected with a U.S. trade or business or permanent establishment, and (2) is entitled to deductions and credits under a Tax Treaty; validity of Treasury Regulations requiring foreign corporations to file a tax return by a date certain to claim deductions
|
Judgment for government
|
Robert C. Morris |
Barbara B. Allbritton, Individually and as Co-Executor of the Estate of Joe L. Allbritton, Deceased v. United States of America
|
Southern District of Texas
|
Constructive property distributions of artwork and antiques from a closely-held corporation; rental value for use of corporate properties.
|
Settled
|
Reagan M. Brown
Charles W. Hall
Robert C. Morris
Carter W. Dugan
Richard L. Hunn
|
Citizen of Panama who was the owner of an international cattle transport business and was the target of a federal criminal tax and money laundering grand jury investigation
|
U.S. Attorney’s Office for the Southern District of Florida
|
International money laundering scheme and filing false corporate and individual returns relating to receipt of funds
|
Declination of charges
|
Mayling C. Blanco |
Anthony W. Wang & Lulu C. Wang v. Commissioner
|
Tax Court
|
Whether sales of automobiles were subject to collectible capital gains rate
|
Government conceded
|
Jasper G. Taylor III
Richard L. Hunn
|
Bruce L. Downey & Deborah H. Downey v. Commissioner
|
Tax Court
|
Valuation of LLC interests which were sold to trusts for purposes of determining gift tax liability and/or accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
Perpetual Corporation, Inc. v. United States of America
|
Southern District of Texas
|
Gain from the purported distribution of artwork to a shareholder, and/or the expiration of the statute of limitations for assessment
|
Government conceded
|
Reagan M. Brown
Charles W. Hall
Robert C. Morris
Carter W. Dugan
Richard L. Hunn
|
Humboldt Shelby Holding Corporation and Subsidiaries v. Commissioner
606 F. App’x 20 (2d Cir. 2015)
|
Second Circuit Court of Appeals
|
Correct legal standard in analyzing the economic substance doctrine
|
Judgment affirmed
|
Jasper G. Taylor III
Richard L. Hunn |
James Haber v. United States
115 A.F.T.R. 2d 2015-2221 (S.D.N.Y. 2015)
|
Southern District of New York
|
Validity of IRS summons issued while a Justice Department referral was in effect; whether summons was in aid of collection
|
Judgment for government; taxpayer appealed
|
Jasper G. Taylor III
Richard L. Hunn
|
ADAMS Offshore Services, Ltd. v. Commissioner of Internal Revenue
|
Tax Court
|
Whether a foreign company (1) has income connected with a U.S. trade or business or permanent establishment, and; (2) timely filed its Tax Court petition outside of the general 150-day filing period
|
Judgment for taxpayer on timely filing issue; Government conceded the U.S. trade or business / permanent establishment issues
|
Robert C. Morris |
Kathy S. Hodge v. Commissioner of Internal Revenue
|
Tax Court
|
Economic development credits, residency issues, and/or penalties
|
Settled residency issue; government conceded penalty issue as part of settlement
|
Robert C. Morris |
Jim C. Hodge v. Commissioner of Internal Revenue
|
Tax Court
|
Economic development credits, residency issues, and/or penalties
|
Settled residency issue; government conceded penalty issue as part of settlement
|
Robert C. Morris |
Steven A. Carr v. Commissioner
|
Tax Court
|
Taxability of disbursements received in connection with estate administration
|
Government conceded
|
Robert C. Morris
Richard L. Hunn
|
The Diversified Group Incorporated and James Haber v. United States
123 Fed. Cl. 442 (2015)
|
Court of Federal Claims
|
Whether pre-2004 section 6707 penalties are divisible taxes and thus subject to Court of Federal Claims’ jurisdiction
|
Judgment for government; case appealed
|
Jasper G. Taylor III
Richard L. Hunn
|
Robert L. Allbritton and Elena H. Allbritton v. Commissioner of Internal Revenue
|
Tax Court
|
Fair rental value of property
|
Settled
|
Robert C. Morris
Charles W. Hall
|
Benjamin and Sharon Soleimani v. Commissioner
|
Tax Court
|
Appropriateness of tax losses due arising from the expropriation of property by Iranian government.
|
Pending
|
Mayling C. Blanco |
James Haber, Transferee v. Commissioner
|
Tax Court
|
Transferee liability and alter ego or agent
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
Jayash M. Chadha
|
Gerdau Macsteel Inc. and Affiliated Subsidiaries v. Commissioner
|
Fifth Circuit Court of Appeals
|
Whether corporate restructuring transactions involving assumption of contingent liabilities resulted in capital losses; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn |
Estate of Harold N. Carr, Deceased, Steven Addison Carr, Independent Executor, v. Commissioner of Internal Revenue
|
Tax Court
|
Valuation of oil and gas producing properties
|
Settled
|
Robert C. Morris |
Crescent Holdings LLC, Arthur W. & Joleen H. Fields, A Partner Other Than the Tax Matters Partner v. Commissioner
141 T.C. 477 (2013)
|
Tax Court
|
Whether an individual should be treated as a partner for purposes of allocating partnership items (represented tax matters partner)
|
Split decision
|
Jasper G. Taylor III
Richard L. Hunn
|
MT Avenue Investor Partners, MJT Park Investors, Inc., Tax Matters Partner v. Commissioner et al.
|
Tax Court
|
Whether taxpayers are liable for accuracy-related penalties with respect to partnership transactions involving swaps and options
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
Merck & Co,. Inc. v. United States
652 F.3d 475 (3d Cir.2011)
|
Third Circuit Court of Appeals
|
Whether (1) a transaction can be recharacterized as a loan under the economic substance doctrine, step-transaction doctrine, or substance over form doctrine, and (2) the IRS had impermissibly discriminated against a taxpayer by denying it equal treatment with another taxpayer
|
Judgment affirmed
|
Charles W. Hall
Reagan M. Brown
Robert C. Morris
Jonathan S. Franklin
|
YRC Regional Transportation Inc. and Subsidiaries f.k.a. USF Corporation & Subsidiaries v. Commissioner
|
Tax Court
|
Worthless stock or debt deduction with respect to stock of a subsidiary
|
Settled
|
Richard L. Hunn
Robert C. Morris
|
United American Housing & Education Foundation v. United States of America
|
District of Columbia
|
Declaratory judgment action regarding whether IRS could retroactively revoke the tax-exempt status of an entity
|
Settled
|
Robert C. Morris |
Valero Energy Corp. v. United States
569 F.3d 626 (7th Cir. 2009)
|
Seventh Circuit Court of Appeals
|
Tax shelter exception to section 7525 tax practitioner privilege
|
Judgment affirmed
|
Jonathan Franklin
Richard L. Hunn
Robert C. Morris
|
Carol Whalen v. Commissioner
|
Fifth Circuit Court of Appeals
|
Whether IRS erred in failing to credit taxpayer with federal income tax withholding for amount that was remitted to IRS during tax year at issue
|
Settled
|
Stephen A. Kuntz
Richard L. Hunn
|
Eugene Campbell 2004 Revocable Trust, James H. Jasper, Trustee, Charles E. Campbell II Trust, James H. Jasper, Trustee, et al. v. Commissioner
|
Tax Court
|
Whether IRS erred in determining that upon the death of decedent direct skips occurred when assets were distributed, resulting in additional GST tax
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
Estate of Charles E. Campbell, Deceased, Judy Stark Campbell, Independent Executrix v. Commissioner
|
Tax Court
|
Valuation of interests in limited partnerships and limited liability companies
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
The Markell Company, Inc. v. Commissioner
T.C. Memo. 2014-86
|
Tax Court
|
Whether option transactions, corporate transactions, and partnership transactions lacked economic substance; accuracy-related penalties
|
Judgment for government
|
Jasper G. Taylor III
Richard L. Hunn
|
Vance Finance and Holding Corporation and Subsidiaries v. Commissioner
|
Tax Court
|
Whether option transactions, corporate transactions, and partnership transactions lacked economic substance; accuracy-related penalties
|
Case dismissed on taxpayers’ motion
|
Jasper G. Taylor III
Richard L. Hunn
|
Valero Energy Corp. v. United States
2007 U.S. Dist. LEXIS 81526 (N.D. Ill. Aug. 23, 2007)
2008 U.S. Dist. LEXIS 105609 (N.D. Ill. Aug. 26, 2008)
|
Northern District of Illinois
|
IRS summons; section 7525 tax practitioner privilege and tax shelter exception
|
Split decision
|
Richard L. Hunn
Robert C. Morris
|
Shell Petroleum Inc. v. United States
2008 U.S. Dist. LEXIS 51180 (S.D. Tex. July 3, 2008)
|
Southern District of Texas
|
Whether the IRS could deny losses on the grounds that a related transaction lacked a business purpose and economic substance
|
Judgment for taxpayer
|
Charles W. Hall
Robert C. Morris
|
HBS Investments, LLC, Humboldt Corporation, A Partner Other Than the Tax Matters Partner v. Commissioner
|
Tax Court
|
Validity of notice of final partnership administrative adjustment
|
Case dismissed for lack of jurisdiction on unopposed motion
|
Jasper G. Taylor III
Richard L. Hunn
|
Humboldt Shelby Holding Corporation and Subsidiaries v. Commissioner
T.C. Memo. 2014-47
|
Tax Court
|
Whether option transactions and partnership transactions lacked economic substance; accuracy-related penalties
|
Judgment for government
|
Jasper G. Taylor III
Richard L. Hunn
|
Schering-Plough Corp. v. United States
2007 WL 4264542 (D. N.J. Dec. 3, 2007)
651 F. Supp. 2d 219 (D. N.J. 2009)
|
District of New Jersey
|
Whether (1) a transaction can be recharacterized as a loan under the economic substance doctrine, step-transaction doctrine, or substance over form doctrine, and (2) the IRS had impermissibly discriminated against a taxpayer by denying it equal treatment with another taxpayer
|
Judgment for government
|
Charles W. Hall
Reagan M. Brown
Robert C. Morris
|
Ironbridge Corp. And Subsidiaries f.k.a. Pitt-Des Moines, Inc., et al. v. Commissioner
|
Tax Court
|
Whether option transactions, corporate transactions, and partnership transactions lacked economic substance; accuracy-related penalties
|
Case dismissed on taxpayers’ motion
|
Jasper G. Taylor III
Richard L. Hunn
|
Carol Whalen v. Commissioner
T.C. Memo. 2009-37
|
Tax Court
|
Whether IRS erred in failing to credit taxpayer with federal income tax withholding for amount that was remitted to IRS during tax year at issue
|
Judgment for government; case settled on appeal
|
Richard L. Hunn
Stephen A. Kuntz
Joseph C. Sleeth, Jr.
|
Iron Investments 2002 LLC, Ironbridge Corp., A Partner Other Than the Tax Matters Partner v. Commissioner
|
Tax Court
|
Validity of notice of final partnership administrative adjustment
|
Case dismissed for lack of jurisdiction on unopposed motion
|
Jasper G. Taylor III
Richard L. Hunn
|
MC Investments 2002 LLC, Markell Corporation, A Partner Other Than the Tax Matters Partner v. Commissioner
|
Tax Court
|
Validity of notice of final partnership administrative adjustment
|
Case dismissed for lack of jurisdiction on unopposed motion
|
Jasper G. Taylor III
Richard L. Hunn
|
VCO Investments LLC, Vance Finance and Holding Corp., A Partner Other Than the Tax Matters Partner v. Commissioner
|
Tax Court
|
Validity of notice of final partnership administrative adjustment
|
Case dismissed for lack of jurisdiction on unopposed motion
|
Jasper G. Taylor III
Richard L. Hunn
|
New Capital Fire, Inc. v. Commissioner
|
Tax Court
|
Whether corporate transactions failed to qualify as an F reorganization, resulting in step-up in basis for successor corporation
|
Pending
|
Jasper G. Taylor III
Richard L. Hunn
|
Estate of Judith J. Leftwich Calder, Deceased, Howard C. Calder, Personal Representative v. Commissioner
|
Tax Court
|
Estate tax marital deduction for qualified terminal interest property
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
John H. & Katherine E. Powers v. Commissioner
|
Tax Court
|
Disallowance of professional fees as related to transactions lacking economic substance, flow-through losses for lack of substantiation; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
Rebecca L. LeBlanc v. Commissioner
|
Tax Court
|
Disallowance of professional fees as related to transactions lacking economic substance; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
Lewis Nicholas Powers v. Commissioner
|
Tax Court
|
Disallowance of professional fees as related to transactions lacking economic substance; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
La Git 88 Trust, Kenneth A. Keeling, Trustee v. Commissioner
|
Tax Court
|
Disallowance of professional fees as related to transactions lacking economic substance; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
AFFCO Investments 2001, L.L.C., AFFCO L.L.C., Tax Matters Partner v. United States
|
Eastern District of Louisiana
|
Whether partnership and option transactions lacked economic substance; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
Starlike Properties, Inc. v. Commissioner
|
Tax Court
|
Whether option transactions lacked economic substance; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
Igor M. & Jeanne M. Olenicoff v. Commissioner
|
Tax Court
|
Whether taxpayers had unreported income; civil fraud penalties
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
HE Sargent, Inc. v. United States
|
Court of Federal Claims
|
Whether taxpayer owed employment taxes with respect to vehicle rental payments that it made to its employees for use of their vehicles
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
Jayash M. Chadha
|
William B. & Anne H. Russell v. Commissioner
|
Tax Court
|
Valuation of shares of stock for gift tax purposes
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
Tiger Bay Limited Partnership, IPS Avon Park Corporation, A Partner Other Than the Tax Matters Partner v. Commissioner
|
Tax Court
|
Whether taxpayers’ sale of power purchase agreements constituted a termination, thus ineligible for capital gains treatment; whether consent to extend period of limitations was valid
|
Settled
|
Jasper G. Taylor III
R. Richard Coston
Richard L. Hunn
|
United States v. Jayne Taylor
|
Ninth Circuit Court of Appeals
|
Whether IRS summonses were overbroad, vague, and petitions to enforce brought in bad faith
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
United States v. Jayne Taylor
|
Central District of California
|
Whether IRS summonses were overbroad, vague, and petitions to enforce brought in bad faith
|
Judgment for government; settled on appeal
|
Jasper G. Taylor III
Richard L. Hunn
|
Shell Petroleum, Inc. v. United States
319 F.3d 1334 (Fed. Cir. 2003)
|
Federal Circuit Court of Appeals
|
Whether hydrocarbons constituted tar sands for purposes of tax credit for nonconventional fuels under section 29
|
Judgment affirmed
|
Charles W. Hall |
Olen Residential Realty Corp., (f.k.a. The Olen Company) and Subsidiaries, et al. v. Commissioner
|
Tax Court
|
Disallowance of interest expense and treatment of bank deposits as income to taxpayers based on allegation that third party was foreign related party; accuracy-related penalties
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
Jayash M. Chadha
|
Gerdau Macsteel Inc. and Affiliated Subsidiaries v. Commissioner
139 T.C. 67 (2012)
|
Tax Court
|
Whether corporate restructuring transactions involving assumption of contingent liabilities resulted in capital losses; accuracy-related penalties
|
Judgment for government on tax issue, split decision on penalties; case settled on appeal
|
Jasper G. Taylor III
Richard L. Hunn
|
The Diversified Group Incorporated and Subsidiaries, et al. v. Commissioner
|
Tax Court
|
Whether equipment rental expenses from sale-leaseback transactions were deductible as business expenses; whether the transactions lacked economic substance
|
Settled
|
Jasper G. Taylor III
William H. Caudill
Richard L. Hunn
|
Browning-Ferris Industries, Inc. v. United States
233 F. Supp. 2d 1223 (D. Ariz. 2002)
|
District of Arizona
|
Whether settlement converted investment tax credit into nonpartnership item
|
Judgment for taxpayer
|
Stephen A. Kuntz
|
Riggs National Corp. v. Commissioner
295 F.3d 16 (D.C. Cir. 2002)
|
District of Columbia Circuit Court of Appeals
|
Foreign tax credit for foreign withholding taxes related to Brazilian loans
|
Judgment for taxpayer
|
Charles W. Hall |
Prudential Overall Supply v. Commissioner
T.C. Memo. 2002-103
|
Tax Court
|
Whether the IRS abused its discretion in imposing a change of accounting method requiring taxpayer to capitalize and depreciate industrial laundry items
|
Judgment for taxpayer
|
Jasper G. Taylor III
Richard L. Hunn
Jayash M. Chadha
|
Succession of Helis v. United States
88 A.F.T.R. 2d 2001-5199 (Fed. Cl. 2001)
52 Fed. Cl. 745 (2002)
56 Fed. Cl. 544 (2003)
|
Court of Federal Claims
|
Valuation of oil and gas partnership interest; administrative expense deductions for excess interest and executor and attorneys’ fees
|
Judgment for taxpayer on all issues except excess interest deduction
|
Jasper G. Taylor III
Charles W. Hall
William H. Caudill
|
Estate of Ruth Baker, Deceased, Mary E. Knowles, f.k.a. Mary Elizabeth Baker, Co-Executrix and Cody Dutton, Co-Executor v. Commissioner
|
Tax Court
|
Discounts for interests in family limited partnership in estate tax case
|
Settled
|
Jasper G. Taylor III
Richard L. Hunn
|
Laborers’ International Union of North America v. Commissioner
T.C. Memo. 2001-171
|
Tax Court
|
Unrelated business taxable income; statute of limitations
|
Judgment for taxpayer
|
Jasper G. Taylor III
Richard L. Hunn
|
Shell Petroleum, Inc. v. United States
50 Fed. Cl. 524 (2001)
|
Court of Federal Claims
|
Whether hydrocarbons constituted tar sands for purposes of tax credit for nonconventional fuels under section 29
|
Judgment for government
|
Charles W. Hall |
Estate of Hubbard v. Commissioner
|
Tax Court
|
Estate tax valuation of satellite television assets
|
Settled
|
Charles W. Hall |
Union Texas International Corp. v. Commissioner
110 T.C. 321 (1998)
|
Tax Court
|
Windfall profits tax: whether taxpayer was independent producer for purposes of limitations on percentage depletion; net interest limitations on calculation of tax
|
Split decision
|
Jasper G. Taylor III
Charles W. Hall
William H. Caudill
|
Shell Petroleum, Inc. v. United States
996 F. Supp. 361 (D. Del. 1997)
|
District of Delaware
|
Whether hydrocarbons constituted tar sands for purposes of tax credit for nonconventional fuels under section 29
|
Judgment for government
|
Charles W. Hall |
Coca-Cola Co. v. Commissioner
106 T.C. 1 (1996)
|
Tax Court
|
Computation of combined taxable income for purposes of credit under section 936 for operations in a U.S. possession
|
Judgment for taxpayer
|
Charles W. Hall |
TRT Holdings, Inc. v. Commissioner
|
Tax Court
|
Whether transaction qualified as tax free reorganization
|
Settled
|
Charles W. Hall
R. Richard Coston
|