March 11, 2025
Sam Lapin (LAW ’17), Maria O’Toole Jones, and Omar M. Hussein discuss the Department of the Treasury and the IRS designating Syndicated Conservation Easement transactions as listed transactions.
April 10, 2024
In Culp v. Commissioner, the Third Circuit held that § 6213(a)’s 90-day period for filing a Tax Court petition to redetermine a deficiency is not jurisdictional and is subject to equitable tolling. Relaxing strict compliance with the draconian filing rule would allow taxpayers to have their day in court even if they fail to meet the 90-day deadline.
Robert M. Kane, Jr. examines Pope & Talbot and argues that the IRS inappropriately relied on that case in two rulings addressing the calculation of section 311 gain on distributions of partnership equity.
On November 20, 2019 Chief Judge Maurice Foley of the U.S. Tax Court delivered this year’s Fogel Lecture at Temple Law School, which he dubbed “Pathways and Pitfalls, A Candid Discussion of My Path to the Bench.” Before becoming the first African-American appointed to the United States Tax Court in 1995, Judge Foley was an attorney for the Legislation and Regulations Division of the Internal Revenue Service, Tax Counsel for the United States Senate Committee on Finance, and Deputy Tax Legislative Counsel in the U.S. Treasury’s Office of Tax Policy.
Second in a series of four primers on the key legal regimes incentivizing and protecting whistleblowers who report fraud: the False Claims Act (FCA) and the Securities Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC) and Internal Revenue Service (IRS) whistleblower programs.
This article is the first in a series of four primers on the key legal regimes incentivizing and protecting whistleblowers who report fraud: the False Claims Act (FCA) and the Securities Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), and Internal Revenue Service (IRS) whistleblower programs.