United States, 2020 WL 1966847 (April 24, 2020), a recent tax shelter decision ... determine whether there was a reasonable basis for the taxpayer’s position. This argument may frame later ...

A member may prepare or sign a return when there is a reasonable basis for the tax return position and it is adequately disclosed. This is consistent with Circular 230’s requirements. As with all tax ...

JDA’s after-tax profit as a percentage ... that individuals in positions subordinate to Watson were paid significantly more in compensation. To quantify the amount of reasonable compensation ...

We believe that reasonable ... in basis, and then filing an amended tax return requesting a refund based on the assets receiving a step-up in basis, and providing full disclosure that this ...

A while ago, we wrote about Form 8275, Disclosure Memo, as a safety tool to avoid penalties by disclosing a position on a tax return for which the preparer and taxpayer believe they have reasonable ...

The Tax Court has used both the “independent investor test” and the “multiple-factor approach” to evaluate whether compensation is reasonable ... close to the assumed rate of return, a factor favoring ...

“the Reagan recovery grew at 4.9 percent.” Raising taxes on the wealthiest Americans, who could still afford to live in utter splendor while contributing a reasonable amount to help repair a ...