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Continuing Impact of Notable Tax Cases: Applying Landmark Tax Decisions to Current Tax Matters

Cohan Rule, Duberstein v. Commissioner, Welch v. Helvering, Glenshaw Glass Co.

Note: CLE credit is not offered on this program

A live 110-minute CPE webinar with interactive Q&A

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Friday, June 21, 2024 (in 6 days)

1:00pm-2:50pm EDT, 10:00am-11:50am PDT

(Alert: Event date has changed from 5/29/2024!)

or call 1-800-926-7926

This webinar will review several of the most influential tax cases of all time. Our panel of astute tax controversy attorneys will highlight the original decisions' pertinent aspects, review current rulings citing these cases, and explain how these decisions should and do apply to current tax matters.

Description

Landmark tax cases charted the course for tax calculations and continue to impact decisions made by the courts and taxpayers. These remarkable rulings are frequently revisited and cited as preparers navigate the complexities of the Internal Revenue Code.

As famous for its namesake, George M. Cohan, as its tax implications, the Cohan Rule resulted from the resolution reached in Cohan v. Commissioner, 39 F.2d 540 (2d Cir. 1930). The Cohan Rule allows taxpayers to deduct reasonably estimated expenses when complete records do not exist. Recently, in Alvarado v. Commissioner (U.S.T.C. Jan. 3, 2024), the court allowed Alvarado, a used car dealer, to avoid fraud penalties and estimate his cost of goods, citing the Cohan Rule.

United States v. Boyle, 469 US 241 (S. Ct. 1985) is another significant case with continuing impact. Boyle established that reliance on a tax preparer does not constitute reasonable cause for unfiled or late-filed tax returns. The U.S. Court of Appeals for the Eleventh Circuit recently cited this case in its decision relative to e-filed returns, Lee v. U.S. 84 F.4th 1271 (11th Cir. Oct. 24, 2023). The court determined that the Boyle decision applied to electronically filed tax returns as well as paper.

Tax practitioners and advisers should be familiar with the key elements of the most influential tax cases and understand how they are being applied to tax decisions today.

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Outline

  1. Notable tax cases: introduction
  2. Cohan v. Commissioner
  3. Duberstein v. Commissioner
  4. United States v. Boyle
  5. Welch v. Helvering
  6. Commissioner v. Glenshaw Glass Co.
  7. Gregory v. Helvering
  8. Other notable decisions

Benefits

The panel will cover these and other critical issues:

  • Highlights of landmark tax rulings that continue to influence tax matters today
  • When the Cohan Rule can provide significant tax benefits for certain taxpayers
  • How key tax cases influence the determination of ordinary and necessary business expenses under IRC Section 162
  • Analyzing and applying key elements of the most influential tax decisions

Faculty

Davis, Evan
Evan J. Davis

Principal
Hochman Salkin Toscher Perez

Mr. Davis joined the firm in 2016 after more than 20 years in the public sector as a trial lawyer with extensive...  |  Read More

Horwitz, Robert
Robert Horwitz

Principal
Hochman Salkin Toscher Perez

Mr. Horwitz has over 35 years of experience as a tax attorney specializing in the representation of clients in civil...  |  Read More

Kalinski, Jonathan
Jonathan Kalinski

Principal
Hochman Salkin Toscher Perez

Mr. Kalinski specializes in both civil and criminal tax controversies as well as sensitive tax matters including...  |  Read More

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