Jeffrey M. Glassman
Subscribe to Jeffrey M. Glassman's PostsJeffrey M. Glassman is experienced in defending businesses and individuals in all stages of federal tax controversies. He represents clients in US Internal Revenue Service (IRS) examinations, administrative appeals, voluntary disclosures, and litigation. Jeffrey has settled multiple tax disputes with IRS legal counsel avoiding litigation in court, when possible. He has significant experience advising clients on strategic and procedural considerations in US Tax Court and other federal courts. Read Jeffrey Glassman's full bio.
Tax Court: Mailbox Rule Can Apply with Stamps.com Postage Label
By Jeffrey M. Glassman and McDermott Will & Emery on Dec 5, 2017
Posted In Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized
Within the Internal Revenue Code (Code) is a rule commonly known as the “mailbox rule” or the “timely mailed, timely filed rule.” Under Code Section 7502(b), the date that an item—including a Tax Court petition—is postmarked and mailed can also be the date the item is considered filed. When an item is received after the...
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Tax Court Says IRS’s “Drift-Net” Argument to Expand Privilege Waiver Must Be Anchored in Principles
By Jeffrey M. Glassman, Kevin Spencer, Robin L. Greenhouse and Roger J. Jones on Nov 3, 2017
Posted In Court Procedure Matters, IRS Audits, IRS Guidance, Privilege and Non-Disclosure, Trial Courts, Uncategorized
In Estate of Levine v. Commissioner, the US Tax Court (Tax Court) rejected an Internal Revenue Service (IRS) attempt to expand upon the privilege waiver principles set forth in AD Inv. 2000 Fund LLC v. Commissioner. As background, the Tax Court held in AD Investments that asserting a good-faith and reasonable-cause defense to penalties places...
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TIGTA Report: FOIA Procedures Need Improvement
By McDermott Will & Emery and Jeffrey M. Glassman on Oct 3, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized
On September 7, 2017, the Treasury Inspector General for Tax Administration (TIGTA) issued a report about the Internal Revenue Service’s (IRS) Freedom of Information Act (FOIA) procedures. After reviewing a statistically valid sample of FOIA requests, TIGTA concluded that the IRS improperly withheld information 14.3 percent of the time—or approximately 1 in 7 FOIA requests....
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Sovereign Immunity Principles Bar Taxpayers from Challenging John Doe Summonses
By Jeffrey M. Glassman and McDermott Will & Emery on Aug 17, 2017
Posted In IRS Guidance, Trial Courts, Uncategorized
We recently wrote here about “John Doe” summonses and a case where an anonymous “John Doe” was allowed to intervene in a summons enforcement action. To refresh, under Internal Revenue Code (IRC) Section 7602 the Internal Revenue Service (IRS) has broad authority to issue administrative summonses to taxpayers and third parties to gather information to...
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President Trump Nominates Copeland and Urda to US Tax Court
By Jeffrey M. Glassman, Kevin Spencer and McDermott Will & Emery on Aug 7, 2017
Posted In Court Procedure Matters, Trial Courts, Uncategorized
On August 3, 2017, President Donald Trump nominated two judges to the US Tax Court. The nominations were received in the US Senate (Senate) and referred to the Committee on Finance. One of the nominees, Elizabeth Copeland, was previously nominated by President Barack Obama. Her previous nomination expired with the conclusion of the 114th Congress...
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LB&I’s Final Campaigns Webinar: Section 48C Energy Credits and Completed Contract Method for Land Developers
By Jeffrey M. Glassman and McDermott Will & Emery on Jun 27, 2017
Posted In IRS Audits, IRS Guidance, Tax Refunds, Uncategorized
On June 20, 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) hosted its final webinar regarding LB&I Campaigns. Our previous coverage of LB&I Campaigns can be found here. The webinar focused on two campaigns: (1) Section 48C Energy Credits and (2) Land Developers – Completed Contract Method.
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The View from Here: LB&I’s Cross-Border Activities Campaigns Webinar
By Jeffrey M. Glassman and McDermott Will & Emery on May 25, 2017
Posted In IRS Audits, IRS Guidance, Transfer Pricing Resource, Uncategorized
On Tuesday, May 23, 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) hosted its sixth in a series of eight webinars regarding LB&I Campaigns. Our previous coverage of LB&I Campaigns can be found here. The webinar focused on two cross-border activities campaigns: (1) the Repatriation Campaign and (2) the Form 1120-F...
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APA Challenge to Notice of Deficiency: QinetiQ Requests Supreme Court Review
By Jeffrey M. Glassman and Roger J. Jones on Apr 13, 2017
Posted In Appellate Courts, Court Procedure Matters, IRS Guidance, Trial Courts, Uncategorized
On April 4, 2017, QinetiQ U.S. Holdings, Inc. petitioned the US Supreme Court to review the US Court of Appeals for the Fourth Circuit’s decision that the Administrative Procedure Act of 1946 (APA) does not apply to the Internal Revenue Service (IRS) Notices of Deficiency. We previously wrote about the case (QinetiQ U.S. Holdings, Inc....
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Understanding LB&I “Campaigns” – The Second Webinar
By Jeffrey M. Glassman on Apr 13, 2017
Posted In IRS Audits, IRS Guidance, Uncategorized
On March 28, 2017, EY and the Internal Revenue Service (IRS) held a joint webcast presenting the Large Business & International’s (LB&I) new “Campaign” examination process. This was the IRS’s second in a planned eight-part series about Campaigns. The IRS speakers for the presentation were Tina Meaux (Assistant Deputy Commissioner Compliance Integration) and Kathy Robbins...
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Battat v. Commissioner: A Primer on the History of the US Tax Court
By McDermott Will & Emery and Jeffrey M. Glassman on Feb 9, 2017
Posted In Court Procedure Matters, Trial Courts, Uncategorized
In Battat v. Commissioner, the US Tax Court recently affirmed its own constitutionality, in releasing an opinion relating to the President’s authority to remove Tax Court Judges. The taxpayer filed a motion asking the court to disqualify all Tax Court Judges and to declare unconstitutional IRC Section 7443(f), which provides circumstances by which the President...
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