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Government filed a motion to expedite the appeal of the Loving Decision

On April 1, 2013, the Government, on behalf of the Internal Revenue Service and the Commissioner, filed a motion in the US Court of Appeals, District Court of Columbia Circuit, to expedite the Government’s appeal of the Loving decision. The counsel for the Government argued that the appellee’s answering brief be due by May 17,…

Supreme Court Takes Case on §6662 Penalty for Overstatement of Basis

On March 25th, the Supreme Court granted the government’s petition for certiorari in United States v. Woods, No. 12-562. The issue raised in the petition concerns the applicability of the valuation overstatement penalty to an overstatement of basis. The case involves overstatement of basis attributable to a transaction lacking “economic substance” and thus disregarded for…

Governor Hassan doubles and permanently extends R&D tax credit

On March 21, 2013, Governor Maggie Hassan (NH D) signed bipartisan legislation to increase the research and development (R&D) tax credit fund to $2 million and extend it permanently. The expansion of the R&D credit is a key provision of the Governor’s innovation plan to help businesses grow and create jobs in the state of…

Much Ado About UCC II: Analyzing the Recent Dow Case

John Dies is a director, Jeremy Fingeret is a senior managing director, and Scott Weese is an associate in the Tax Controversy Services Department of alliantgroup LLP. Contrary to early concerns, the recent Second Circuit opinion in Union Carbide Corp. (UCC II) merely reinforces the status quo allowing taxpayers to claim any supply cost for…
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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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