International Taxation
Assessee Not Liable To Be Taxed On Cancellation Of Indebtedness Income: US Tax Court
The US Tax Court held that the assessee is not liable for tax on cancellation of indebtedness income but is liable for tax rental...
Settlement Officer Didn’t Abuse Discretion In Rejecting Offer-In-Compromise-Effective Tax Administration Based On Economic Hardship: US Tax Court
The United States Tax Court has held that the settlement officer (SO) did not abuse discretion in rejecting offer-in-compromise-effective tax administration based on economic...
US Tax Court Dismisses Case On Failure Of Dept. Prove Deficiency Notice Properly Mailed To Assessee
Just like Indian Tax Department, the US tax department has failed to prove that the deficiency notice was properly mailed to assessee, consequently, the...
Failure Of Assessee To Prove Business Activity, Tax Deduction Not Allowable: US Tax Court
The United States Tax Court has held that taxpayers/assessees have failed to demonstrate that they were carrying on a trade or business themselves or...
Corporation’s Net Income To Be Considered As Taxpayer’s Income Even Though Not Received By Him: US Tax Court
The United States Tax Court has held that the corporation’s net income was the taxpayer’s even though he’d received nowhere near that amount in...
Owner Of Capital Interest In Partnership Be Recognized As Partner Regardless Of Participation: US Tax Court
The United States Tax Court has held that the owner of a capital interest in a partnership be recognized as a partner regardless of...
Ex-Wife Not Involved In Business Decision During Husband’s Affair, Gets Relief From Couple’s Joint Tax Debts : US Tax Court
The US Tax Court gave relief to the ex-wife not involved in a business decision during the husband's affair, from the couple's joint tax...
Canada-U.S. Income Tax Treaty Bars Collections Hearing By United States: U.S. Tax Court
The United States Tax Court has held that Canada-U.S. Income Tax Treaty bars collections hearing by the United States.The court opined that it would...