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.
Ax v. Commissioner: The Tax Court Reaffirms that It Is Not Subject to the APA
By Jeffrey M. Glassman and McDermott Will & Emery on Apr 12, 2016
Posted In Appellate Courts, Court Procedure Matters, Trial Courts, Uncategorized
On April 11, 2016, the US Tax Court issued its T.C. opinion in Ax v. Commissioner. The notice of deficiency in the case determined that certain premium payments made to a captive insurance company were not established by the taxpayer to be (1) insurance expenses and (2) paid. But this is not a run of...
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Deference Principles in Tax Cases and the Unique Challenges of Auer Deference
By Jeffrey M. Glassman and McDermott Will & Emery on Mar 28, 2016
Posted In Appellate Courts, Court Procedure Matters, Uncategorized
The Federal Lawyer recently published an article we wrote which discusses how deference principles are applied in tax cases. The article can be accessed here. The Supreme Court of the United States, in Mayo Found. for Med. Educ. & Research v. United States, 562 U.S. 44, 55 (2011), confirmed that tax laws are subject to...
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IRS Releases Practice Unit on Allocation of Interest Expense
By Jeffrey M. Glassman and McDermott Will & Emery on Mar 21, 2016
Posted In IRS Audits, IRS Guidance, Uncategorized
On February 19, 2016, the Internal Revenue Service (IRS) released a 30-plus-page practice unit regarding interest expense of a foreign corporation engaged in a U.S. trade or business. As is the case with all practice units, the IRS cautions that practice units are not official pronouncements of law or directives and cannot be used, cited...
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