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U.S. District Court clears way for PTIN user fees

In Allen Buckley and Allen Buckley LLC v. United States, a U.S. district court in the Northern District of Georgia (not yet published) granted summary judgment in favor of the Defendant, upholding an Eleventh Circuit decision that affirmed the validity of imposing a user fee to obtain a preparer tax identification number (“PTIN”). The Plaintiff…

Supreme Court Refuses to Hear “Amazon-Tax” Case

On December 2nd, 2013 the Supreme Court of the United States denied certiorari in Overstock.com, Inc. v. New York State Department of Taxation and Finance, et al. The case involved the assessment of State sales tax against online retailers. The case, brought by Amazon.com and other online retailers, challenged New York State’s law imposing sales…

IRS Updates Guidance on Offers in Compromise Rejected on “Public Policy” and “Not in the Best Interests of the Government” Grounds

On October 23rd, 2013 the Internal Revenue Service (“IRS”, “Service”) issued a memorandum providing guidance to collections employees regarding the proper criteria and procedures for rejecting offers in compromise under the “not in the best interest of the government” and “public policy” standards. Regarding rejections under the “not in the best interest of the government”…

IRS Ruling on SRLY Limitation Allows Surviving Subsidiary to use Pre-Reorganization Losses

The Internal Revenue Service (“IRS”) issued Private Letter Ruling 105886-13 on July 15th, 2013 regarding the treatment of a subsidiary’s post-merger net positive income, net capital gain and Internal Revenue Code (“IRC”) 38(c) contributions for the purpose of computing a Separate Return Limitation Year (“SRLY”) subgroup’s consolidated net income, consolidated net capital gain and consolidated…
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aNlogo-footer3@2x

Washington D.C.
Willard Office Building, Suite 300 1455 Pennsylvania Ave.
Washington, D.C. 20004
202.888.7006

© 2022 alliantNational. - All Rights Reserved.

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