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EVAN DAVIS, ROBERT S. HORWITZ AND JONATHAN KALINSKI to Speak at Upcoming Strafford Webinar on Continuing Impact of Notable Tax Cases – June 21, 2024

We are pleased to announce that Evan Davis, Robert S. Horwitz and Jonathan Kalinski will be speaking at the upcoming Strafford webinar “Continuing Impact of Notable Cases: Applying Landmark Tax Decisions to Current Tax Matters” Friday, June 21, 2024, 10:00 a.m. – 11:50 a.m. (PST).

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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