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The debate over appellate jurisdiction on federal tax matters has been focused primarily on two issues: how best to achieve greater uniformity in federal tax decisions and whether the diversity in tax jurisdiction compromises the quality of decisions resolving tax disputes or is a strength of the system. [2]
Private letter rulings (PLRs), in the United States, are written decisions by the Internal Revenue Service (IRS) in response to taxpayer requests for guidance. [1] A letter ruling is "a written statement issued to a taxpayer by an Associate Chief Counsel Office of the Office of Chief Counsel or by the Tax Exempt and Government Entities Division that interprets and applies the tax laws to a ...
Marrita Murphy and Daniel J. Leveille, Appellants v. Internal Revenue Service and United States of America, Appellees (commonly known as Murphy v.IRS), [1] is a tax case in which the United States Court of Appeals for the District of Columbia Circuit originally held that the taxation of emotional distress awards by the federal government is unconstitutional.
The IRS does have the option of redacting the text of a private ruling and issuing it as a revenue ruling, which may become binding on all taxpayers and the IRS. "Even if it is clear that the taxpayer did not rely on a revenue ruling, courts will often hold the Service to the position expressed in the revenue ruling." [4]
In August, the IRS provided the so-called private letter ruling to the unnamed company, stating that they could offer workers more flexibility with their 401(k) accounts. At the beginning of each ...
Managing your taxes can be one of the most complex aspects of estate planning and a new IRS rule change continues that trend. The rule, published at the end of March, changes how the step-up in ...
Commissioner of Internal Revenue, 54 T.C. 742 (1970), [1] aff'd on other grounds, 445 F.2d 985 (10th Cir. 1971), [2] cert. denied, 404 U.S. 940 (1971), [3] is a case in which the United States Tax Court stated the principle that where the court of appeals to which an appeal would be made in a given case has already established a rule of ...
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