Elliot Pisem

December 16, 2015 | New York Law Journal

In their Taxation column, David E. Kahen and Elliot Pisem discuss a recent Ninth Circuit decision that agreed with the government position that a policyholder's basis in the stock did not include any part of the premiums paid by the policyholder for insurance, and concluded that the entire proceeds from the subsequent sale of the stock by the policyholder constituted gain.

By David E. Kahen and Elliot Pisem

11 minute read

October 15, 2015 | New York Law Journal

In their Taxation column, Elliot Pisem and David E. Kahen discuss a recent Tax Court decision addressing whether a company engaged primarily in the sale of "residual value insurance" with respect to property such as automobiles, commercial real estate, and commercial equipment may compute its income under favorable IRC provisions relating to "insurance companies."

By Elliot Pisem and David E. Kahen

11 minute read

June 18, 2015 | New York Law Journal

In their Taxation column, Elliot Pisem and David E. Kahen discuss 'Batchelor-Robjohns', which serves as yet another reminder of the numerous potential pitfalls that can frustrate an attempt to obtain relief under §1341 from the harsh income tax results otherwise often attributable to the annual tax accounting principle that is a foundation of income tax accounting.

By Elliot Pisem and David E. Kahen

10 minute read

June 17, 2015 | New York Law Journal

In their Taxation column, Elliot Pisem and David E. Kahen discuss 'Batchelor-Robjohns', which serves as yet another reminder of the numerous potential pitfalls that can frustrate an attempt to obtain relief under §1341 from the harsh income tax results otherwise often attributable to the annual tax accounting principle that is a foundation of income tax accounting.

By Elliot Pisem and David E. Kahen

10 minute read

April 16, 2015 | New York Law Journal

In 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

In 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

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

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

In 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

In 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