Insights & Developments

The U.S. Court of Federal Claims finds that the government established that a number of documents were subject to attorney-client privilege stemming from a dispute where the plaintiffs and IRS disagreed as to whether the plaintiffs should be treated as employers for Federal Income Contribution Act and Federal Unemployment Tax Act purposes. 

There have always been tax advantages to owning a home rather than paying rent.  For one thing, the interest portion of mortgage payments and real estate taxes, unlike rent paid to a landlord, is generally deductible from adjusted gross income, subject to the limits on residential interest and also to the alternative minimum tax which eliminates taxes as deductions. 

The vast majority of President Obama's tax policy priorities are left unchanged in his fiscal year 2011 budget, but the handful of modifications reflect some of the hard decisions he has to confront with an expected $1.56 trillion budget deficit.  

Section 1231 normally is a “taxpayer friendly” section in that any gain from the sale or disposition of a section 1231 asset is treated as a capital gain and if the sale or disposition results in loss, the loss is treated as an ordinary loss.