Attorney Fees in Tax Litigation: Jury Says Yes, Judge Says No

In most litigation, each party pays their own attorney fees regardless of who wins the case. This “American Rule” applies even when one party is clearly right and the other clearly wrong. But litigation against the government, such as tax litigation, presents a unique inequity. When taxpayers are forced to defend against an incorrect IRS……

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The Non-Taxable Return of Capital

Our tax laws acknowledge that a return of capital doesn’t trigger income tax. The fundamental concept is that when property is taken away from a taxpayer and then returned to them, it doesn’t result in an increase in their net worth. Rather, their net worth is restored to where it was before, and since there……

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Tax on Damages for Loss of Consortium

Those who receive damages from physical injuries or sickness are not required to pay tax on the damage award or settlement.  That is the general rule.  But what about ancillary claims by others?  What about a lawsuit for physical damage that also includes a claim for the injured parties spouse?  What if the taxpayer-husband was injured and the……

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