The IRS recently assessed a $290,800 income tax deficiency on CMP Corporation. The deficiency is attributable to a complicated accounting issue involving CMP’s in-vestment in a controlled foreign corporation. CMP plans to contest the deficiency in court. CMP is located in the Third Circuit. Neither the local district court, the Tax Court, nor the Third Circuit Court of Appeals has considered the accounting issue. The Court of Federal Claims and the Eighth Circuit Court of Appeals have decided the issue in favor of the government. However, the Ninth and Tenth Circuit Courts of Appeals have decided the identical issue in favor of the taxpayer. Discuss CMP’s litigation strategy in selecting a trial court.
Answer to relevant QuestionsHow do tax payments differ from other payments that people or organizations make to governmental agencies? One way for the federal government to increase tax revenues would be to enact either a VAT or a national retail sales tax. The U.S. sales tax could be collected in the same manner and at the same time as state and local ...Many local jurisdictions apply a low property tax rate to land owned by privately operated golf courses. What is the economic justification for such a preferential rate? Firm H operates its business in State H, which levies a 6 percent sales and use tax. This year, the firm purchased a $600,000 item of tangible property in State K and paid $18,000 sales tax to the state. It also purchased a ...The federal government levies a gift tax on the value of property that people give away during their life and an estate tax on the value of property that people transfer at death. From the government’s perspective, which ...
Post your question