Earlier this year, I recognized the ten-year anniversary of the landmark Da Silva Moore case that was the first court approval of predictive coding by the now retired New York.
In the early days of Technology Assisted Review (TAR), lawyers were sometimes hesitant about discussing TAR tools with opposing parties and the courts. Apart from a general concern.
Tax Litigation: The Week of May 23rd, 2022, through May 27th, 2022 Albrecht v. Comm’r, T.C. Memo 2022-53 | May 25, 2022 | Greaves, J. | Dkt. No. 13314-20. Genecure, LLC v. Comm’r, T.C. .
One of the most highly litigated issues in U.S. Tax Court is whether taxpayers are liable for certain penalties, additions to tax or additional amounts.
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Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael Jackson’s, estate as shown in the United States Tax Court’s recent 271-page memorandum opinion.
See Estate of Jackson v. Comm’r, T.C. Memo. 2021-48.
Although the lengthy opinion boiled down to general valuation and estate tax principles, it was noteworthy for several reasons. First, the Tax Court explicitly found that the IRS’ expert had perjured himself during trial, resulting in a significant discounting of his offered opinions to the court. Second, the Tax Court was called upon to value significant intangible assets of Mr. Jackson at the time of his death, including his image and likeness. Third, the opinion offers additional insights into how estates, unlike individuals, bear the burden of sho