Edward L. Froelich
By Kevin Spencer, Edward L. Froelich and Evan Walters on Jul 21, 2023
Posted In Appellate Courts, Court Procedure Matters, Trial Courts
On June 1, 2023, in United States v. Liberty Global, Inc., the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies using a common law right of action, bypassing the usual statutory tax deficiency procedures outlined in the Internal...
By Kevin Spencer and Edward L. Froelich on Jul 14, 2023
Posted In Court Procedure Matters, Trial Courts
On July 6, 2023, the US Tax Court issued its decision in Betz v. Commissioner, T.C. Memo. 2023-84. Betz considers the application of the pilot model supply rule to expenses incurred by a designer (CPI) of made-to-order air pollution control systems called oxidizers. At issue was approximately $500,000 of research and development tax credits pursuant...
By Edward L. Froelich on May 26, 2023
Posted In IRS Guidance
Two recent decisions confirmed the broad administrative summons authority of the Internal Revenue Service (IRS). In the first, the US Supreme Court resolved a circuit conflict regarding notice requirements for third-party IRS summonses. In the second, the US Court of Appeals for the Third Circuit confirmed the primacy of the Internal Revenue Code (IRC) over...