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Tax Court Holds State Law Determines Scope of Transferee Liability Under IRC...

In Julia R. Swords Trust v. Commissioner, 142 T.C. 19 (2014), Judge Marvel held in a division opinion that state law – not federal law – determines whether a transaction can be recast to impose...

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Tax Court Holds IRS Can Issue Notice of Intent to Levy While Installment...

In Eichler v. Commissioner, 143 T.C. 2 (July 23, 2014), Chief Judge Thornton holds in a division opinion that—despite the protections in IRC §  6331—the IRS may issue a notice of intent to levy even...

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