Second Circuit Rules Hedge Fund Principals Owe Self-Employment Tax on $141.5 Million
Appeals court adopts functional test for 'limited partner' status, holding that founders who run the business cannot escape the 15.3% tax.
Practice area · Tax
Second Circuit Says IRS May Assess Section 6038(b) Penalties Administratively
The Court of Appeals for the Second Circuit vacated a judgment in Safdieh v. Comm'r and remanded, holding that the Commissioner may assess penalties under Internal Revenue Code Section 6038(b).
11th Circ. Backs IRS In $23M Easement Valuation Fight
The Eleventh Circuit affirmed a Tax Court ruling that valued Savannah Shoals LLC's conservation easement at $480,000 and sustained a gross valuation misstatement penalty.
California Threatens Suit Over DOI Offshore Wind Lease Buyout
California's attorney general says a federal agreement to pay an Invenergy subsidiary to abandon a Central Coast offshore wind lease violates federal offshore leasing law.
Federal Circuit Revives Part Of Contractor's IRS Refund Suit
The Federal Circuit let Dougherty Electric pursue one tax refund theory over IRS fraud penalties and interest, while rejecting a separate supervisor-approval theory as untimely.