In tax rulings, several cases are cited frequently. Many of these cases represent judicial doctrines such as substance over form or step transaction. Some key tax rules, such as the definition of a trade or business or a reasonable cause defense for a penalty waiver, are from court decisions. These key cases and doctrines are not only important to judges, but also to practitioners in compliance and planning work. This webinar presents significant judicial doctrines and rules by identifying and explaining key cases needed to help us better understand and apply our federal tax law. Numerous examples of cases and applications to practice are covered.
Learning Objectives
• Understand various tax doctrines that apply to income recognition, identifying the taxable parties, property transaction calculations, when transactions lack substance, and much more
• Identify when key tax doctrines may be relevant in understanding or supporting a tax treatment or result
• Describe significant court decisions relevant to all aspects of measuring taxable income and being tax compliant
• Identify key rules of statutory construction and their relevance to tax research
Major Topics
• Judicial tax doctrines such as the fruit of the tree, Arrowsmith and dominion and control
• Cases relevant to understanding many areas involved in computing income tax liability and practice and procedure
• Rules of statutory construction and relevance to tax research
• Importance of significant tax cases to compliance, planning and tax research
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