April 16, 2015 | New York Law Journal
Inclusion of Refundable Tax Credits in IncomeIn their Taxation column, David E. Kahen and Elliot Pisem discuss a recent decision of the Tax Court, which concluded that state tax credits that are not needed to reduce actual state tax liabilities to zero and that are nevertheless "refundable" create accessions to wealth required to be included in federal taxable income.
By David E. Kahen and Elliot Pisem
9 minute read
April 15, 2015 | New York Law Journal
Inclusion of Refundable Tax Credits in IncomeIn their Taxation column, David E. Kahen and Elliot Pisem discuss a recent decision of the Tax Court, which concluded that state tax credits that are not needed to reduce actual state tax liabilities to zero and that are nevertheless "refundable" create accessions to wealth required to be included in federal taxable income.
By David E. Kahen and Elliot Pisem
9 minute read
February 19, 2015 | New York Law Journal
'MoneyGram' Tackles Definition of 'Bank'In their Taxation column, Elliot Pisem and David E. Kahen, members of the law firm of Roberts & Holland, discuss a recent Tax Court case that interprets and applies the statutory definition of "bank" in the context of special provisions providing liberal rules under which "banks" may claim deductions for bad debts.
By Elliot Pisem and David E. Kahen
10 minute read
February 18, 2015 | New York Law Journal
'MoneyGram' Tackles Definition of 'Bank'In their Taxation column, Elliot Pisem and David E. Kahen, members of the law firm of Roberts & Holland, discuss a recent Tax Court case that interprets and applies the statutory definition of "bank" in the context of special provisions providing liberal rules under which "banks" may claim deductions for bad debts.
By Elliot Pisem and David E. Kahen
10 minute read
December 18, 2014 | New York Law Journal
Income Classification Pitfalls for Executives of StartupsIn their Taxation column, David E. Kahen and Elliot Pisem of Roberts & Holland discuss a recent Tax Court memorandum decision that tackles various issues faced by key employees of startup businesses.
By David E. Kahen and Elliot Pisem
12 minute read
October 16, 2014 | New York Law Journal
Claim for Bad Tax Advice Results in Nontaxable RecoveryIn their Taxation column, Elliot Pisem and David E. Kahen, members of the law firm of Roberts & Holland, discuss the recent decision in 'Cosentino v. Commissioner', which concludes that certain recoveries against a tax professional are nontaxable as a "replacement of capital" except to the extent it represents a recoupment of amounts previously deducted for income tax purposes by the taxpayer.
By Elliot Pisem and David E. Kahen
10 minute read
August 21, 2014 | New York Law Journal
Deductibility of Payments to Settle False Claims Act LiabilityDavid E. Kahen and Elliot Pisem write about a recent First Circuit decision relating to the deductibility for income tax purposes of a portion of payments made in settlement of Medicare fraud claims under the False Claims Act.
By David E. Kahen and Elliot Pisem
9 minute read
June 19, 2014 | New York Law Journal
Stock Rights Under §457A: Revenue Ruling 2014-18In their Taxation column, Elliot Pisem and David E. Kahen, members of the law firm of Roberts & Holland, write: Rev. Rul. 2014-18 does not appear to reflect any major change in IRS thinking with respect to the treatment of options and SARs under §457A as previously expressed in IRS Notice 2009-8.
By Elliot Pisem and David E. Kahen
9 minute read
April 17, 2014 | New York Law Journal
Loss Deduction for Forfeiture of Insider Trading ProfitsIn their Taxation column, Elliot Pisem and David E. Kahen, members of Roberts & Holland, write about a recent decision of the Court of Federal Claims relating to a court-ordered forfeiture by a corporate executive found to have engaged in illicit insider trading.
By David E. Kahen and Elliot Pisem
11 minute read
February 20, 2014 | New York Law Journal
Property Abandonment Results in Capital Loss: 'Pilgrim's Pride'A recent decision relating to the abandonment of a security has significant implications for the tax treatment of losses arising on the abandonment of all sorts of property, whether or not constituting "securities."
By David E. Kahen and Elliot Pisem
12 minute read