Oakbrook Land Holdings, LLC, et al v. CIR
-
July 15, 2022
Federal Tax Cases To Watch In The Second Half Of 2022
Over the second half of 2022, courts will wade into challenges involving tax administrative law, whether a law firm's mixed client communications are privileged and the potential release of the former president's financial records to congressional committees. Here, Law360 reviews federal tax litigation to watch for the remainder of the year.
-
July 06, 2022
6th Circ. Declines To Revisit Decision Backing Easement Regs
The full Sixth Circuit declined Wednesday to reconsider a panel decision that set up a circuit split by affirming Treasury's compliance with administrative law in issuing a regulation addressing the distribution of proceeds resulting from judicial extinguishments of conservation easements.
-
June 24, 2022
Tax Group Asks 6th Circ. To Rethink Easement Regs Case
The Sixth Circuit should reconsider a panel ruling affirming Treasury's compliance with administrative law in issuing a regulation dealing with conservation easements because the opinion undermines the rulemaking process, a tax advocacy group with Silicon Valley ties told the court.
-
June 14, 2022
6th Circ. Urged To Revisit Decision Backing Easement Regs
The full Sixth Circuit should review a panel ruling affirming Treasury's compliance with administrative law in issuing a regulation dealing with conservation easements, a partnership told the appeals court, arguing the decision threatens to muddle and undermine the regulatory process.
-
March 15, 2022
6th Circ. Affirms Easement Regs, Setting Up Circuit Split
A Treasury regulation addressing the distribution of proceeds resulting from a judicial extinguishment of conservation easements doesn't violate administrative law, the Sixth Circuit said in affirming the rule and arriving at a different conclusion than the Eleventh Circuit.
-
February 11, 2022
4 Tax-Related Administrative Procedure Act Cases To Follow
A recent high-profile case in the Eleventh Circuit has once again demonstrated the power of the Administrative Procedure Act in challenges to IRS regulations alleging that the agency didn't follow the law in crafting regulations or other guidance. Here, Law360 looks at the Hewitt case and others that are primed to influence the extent to which the agency's compliance with administrative requirements may affect its ability to enforce its own guidance.
-
May 24, 2021
Treasury Didn't Craft Easement Rules Properly, 6th Circ. Told
The U.S. Treasury Department violated the Administrative Procedure Act when it improperly crafted a regulation that led to the denial of a land developer's deduction for a $9.5 million conservation easement in Tennessee, the developer told the Sixth Circuit.
-
January 26, 2021
Attys Tell 6th Circ. To Reject Easement Regs In $10M Dispute
A specific Internal Revenue Service argument for denying a tax deduction for a conservation easement is invalid because it is based on a regulation that violates the Administrative Procedure Act, attorneys for an easement donor told the Sixth Circuit.
-
January 03, 2021
Federal Tax Cases To Watch In 2021
In 2021, courts will examine administrative law challenges to microcaptive and conservation easement tax regulations, what qualifies for a domestic manufacturing deduction and whether partnership disguised sale rules apply to an ownership transaction involving the Chicago Cubs baseball team. Here, Law360 looks at four federal tax cases to watch in the first half of the year.