More Securities Loan Cases on Appeal
A while ago we reported on a spate of IRS successes in cases involving purported securities loans (here). The Samueli case is fully briefed in the Ninth Circuit and is expected to be argued in the...
View ArticleFourth Circuit Reverses Tax Court in Virginia Historic
On March 29, 2011, the Fourth Circuit rendered its opinion in Virginia Historic Tax Credit Fund 2001 LP v. Comm’r, No. 10-1333 (opinion linked below). As described in our previous coverage, the case...
View ArticleBriefing Under Way in Anschutz
As we’ve reported in the last few months, several securities lending cases are percolating in the appellate courts (see here and here). On April 29, 2011, Anschutz Company filed the opening brief in...
View ArticleGovernment Files Response in Anschutz
The government filed its response brief in Anschutz Co., et al. v. Commissioner, Nos. 11-9001 & 11-9002 (10th Cir.), on June 22, 2011 (linked below). See our prior coverage here. Not...
View ArticleTenth Circuit Hears Oral Argument in Anschutz
On November 16, the Tenth Circuit heard oral argument in the Anschutz case, involving the taxpayers’ appeal from the Tax Court’s decision to collapse two transactions involving the use of prepaid...
View ArticleUpdate on GI Holdings
In our earlier discussion of the disguised sale cases, we noted that the federal district court in New Jersey had issued an unpublished opinion in the GI Holdings case that applied the disguised sale...
View ArticleTenth Circuit Affirms Tax Court in Anschutz
As we have previously reported (see here, here, and here), in Anschutz the Tax Court collapsed two transactions and held that they amounted to a taxable sale of stock. The Tenth Circuit was unmoved by...
View ArticleThird Circuit Considering Historic Rehabilitation Tax Credits in Historic...
[Note: Miller and Chevalier represents amicus National Trust for Historic Preservation in this case] We present here a guest post by our colleague David Blair who has considerable experience in this...
View ArticleBriefing Completed and Oral Argument Set in Historic Boardwalk Case
[Note: Miller and Chevalier represents amicus National Trust for Historic Preservation in this case] The government has filed its reply brief in the Historic Boardwalk case in the Third Circuit....
View ArticleTax Court Reversed on Historic Rehabilitation Credits in Historic Boardwalk
[Note: Miller & Chevalier filed a brief in this case on behalf of National Trust for Historic Preservation] In a detailed 85-page opinion, the Third Circuit has reversed the Tax Court’s opinion...
View ArticleMore Securities Loan Cases on Appeal
A while ago we reported on a spate of IRS successes in cases involving purported securities loans (here). The Samueli case is fully briefed in the Ninth Circuit and is expected to be argued in the...
View ArticleFourth Circuit Reverses Tax Court in Virginia Historic
On March 29, 2011, the Fourth Circuit rendered its opinion in Virginia Historic Tax Credit Fund 2001 LP v. Comm’r, No. 10-1333 (opinion linked below). As described in our previous coverage, the case...
View ArticleBriefing Under Way in Anschutz
As we’ve reported in the last few months, several securities lending cases are percolating in the appellate courts (see here and here). On April 29, 2011, Anschutz Company filed the opening brief in...
View ArticleGovernment Files Response in Anschutz
The government filed its response brief in Anschutz Co., et al. v. Commissioner, Nos. 11-9001 & 11-9002 (10th Cir.), on June 22, 2011 (linked below). See our prior coverage here. Not...
View ArticleTenth Circuit Hears Oral Argument in Anschutz
On November 16, the Tenth Circuit heard oral argument in the Anschutz case, involving the taxpayers’ appeal from the Tax Court’s decision to collapse two transactions involving the use of prepaid...
View ArticleUpdate on GI Holdings
In our earlier discussion of the disguised sale cases, we noted that the federal district court in New Jersey had issued an unpublished opinion in the GI Holdings case that applied the disguised sale...
View ArticleTenth Circuit Affirms Tax Court in Anschutz
As we have previously reported (see here, here, and here), in Anschutz the Tax Court collapsed two transactions and held that they amounted to a taxable sale of stock. The Tenth Circuit was unmoved by...
View ArticleThird Circuit Considering Historic Rehabilitation Tax Credits in Historic...
[Note: Miller and Chevalier represents amicus National Trust for Historic Preservation in this case] We present here a guest post by our colleague David Blair who has considerable experience in this...
View ArticleBriefing Completed and Oral Argument Set in Historic Boardwalk Case
[Note: Miller and Chevalier represents amicus National Trust for Historic Preservation in this case] The government has filed its reply brief in the Historic Boardwalk case in the Third Circuit....
View ArticleTax Court Reversed on Historic Rehabilitation Credits in Historic Boardwalk
[Note: Miller & Chevalier filed a brief in this case on behalf of National Trust for Historic Preservation] In a detailed 85-page opinion, the Third Circuit has reversed the Tax Court’s opinion...
View Article