References in periodicals archive ?
The CASD usually waives 50 per cent of the required fees when the litigating parties agree to resolve the dispute amicably.
These transactions were created by tax professionals who often neither thought about the potential difficulty of litigating the transactions nor anticipated the analysis in recent court decisions like Coltec and Black & Decker that may embolden government attorneys to attack the portions of real business transactions that appear to have been done to maximize the tax benefits of such transactions.
He now devotes 90 to 95 percent of his practice litigating against HMOs.
The results should follow from selecting the right case to litigate and litigating the case to win.
Hoffer has apparently not drawn on this evidence to support his conclusions about motivations of litigating parties.
In addition to successfully litigating through trial some of the nation's largest environmental claims brought under federal statutes, David Askman is a leading authority on natural resource damages claims," said Washington, DC attorney Michael D.
The IRS's litigating position is contrary to its regulations; see Phillips, 88 TC 529, 534 (1987), aff'd, 851 F2d 1492 (DC Cir.
Litigating Truck Accident Cases, a new release by Michael Jay Leizerman, covers cases involving personal injury, death, and damages caused by trucks or commercial trailers.
It includes information for litigating issues under the Fourth Amendment at all stages of a criminal case, including first meetings, arraignment, negotiations, pretrial motions, hearings, trial and post-trial proceedings.
In a brief amicus curiae filed with the Supreme Court of the United States, Tax Executives Institute called revenue rulings mere litigating positions of the Internal Revenue Service that are not entitled to deference by the courts.
1) Prevailing parties are generally authorized to recover fees expended for successfully litigating the entitlement issue.
My job is to protect this league and the 400-plus players who never get involved in activity like the kind we are litigating, and I feel comfortable that I've acquitted myself the way I'm supposed to.