Elliot Pisem

December 15, 2005 | New York Law Journal

David E. Kahen and Elliot Pisem, members of the law firm of Roberts & Holland, analyze the Tax Court's recent ruling in Federal Home Loan Mortgage Corporation ("FHLMC") v. Commissioner. The principal issue in the case was whether "prior approval purchase contracts" executed by Freddie Mac (the name by which the petitioner is commonly known) were, in substance, options to purchase loans.

By David E. Kahen and Elliot Pisem

10 minute read

April 21, 2011 | New York Law Journal

David E. Kahen and Elliot Pisem, members of Roberts & Holland, review two recent Tax Court memorandum decisions where the court rejected arguments made by the Commissioner for the imposition of transferee liability on selling stockholders.

By David E. Kahen and Elliot Pisem

12 minute read

December 21, 2006 | New York Law Journal

David E. Kahen and Elliot Pisem, members of Roberts & Holland, analyze two cases which present contrasting views of government power in the tax area, with one emphasizing that a government assessment has to have some support to survive a taxpayer challenge and the other emphasizing the deference owed to the Service once it has taken a position on a tax accounting issue.

By David E. Kahen and Elliot Pisem

12 minute read