The Internal Revenue Service has the authority to require taxpayers and some third parties to submit certain records about “reportable transactions.” CIC Services, LLC v. Internal Revenue Serv. at 249. The Internal Revenue Service also defines what...
Internal Revenue Service
Elmer and Dorothy Cullers created the EC Term of Years Trust (“the Trust”), the Petitioner, in 1991 to reduce the impact of federal taxes on their estate. Brief for Petitioner at 3. Two years later, the Internal Revenue Service (the “IRS”) assessed...
In the late 1930s, entrepreneur Margaret Rudkin founded a small business that ultimately developed into
Pepperidge Farm. In 1961, the Campbell Soup Company bought Pepperidge Farm. On April 14th, 1967, Margaret's husband Henry A. Rudkin used...
Between 1992 and 2010, Carlo J. Marinello operated a freight service, Express Courier, in western New York and chose to destroy business records, avoid keeping books, pay his employees in cash, use business income for personal expenses, and avoid...
Self-incrimination is the intentional or unintentional act of providing information that will suggest your involvement in a crime, or expose you to criminal prosecution.
The Fifth Amendment provides protection to individuals...
This case centers on whether a party accusing the Internal Revenue Service (“IRS”) of issuing a summons for an improper purpose is entitled to an evidentiary hearing. See Petition For A Writ of Certiorari at I. The IRS began an investigation into...
n 1999, Respondent Robert Pierce sought to sell his ownership in the Home Oil and Coal Company (“Home Oil”). See Home Concrete & Supply, LLC et. al. v. United States, 634 F.3d 249, 251 (4th Cir. 2011). Based on professional financial advice, Pierce...