Will Congress Extend the Statutory Period For Filing a Petition With the U.S. Tax Court?
September 23, 2025 | Louis Vlahos | Federal
The Latest Last week, an amicus brief was filed with the First Circuit Court of Appeals in support of a taxpayer’s[i] challenge to the U.S. Tax Court’s dismissal of the taxpayer’s petition[ii] for lack of jurisdiction. The Tax Court determined that the taxpayer failed to satisfy the statutory requirement that…
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Cannabis Business and the QBI Deduction
September 17, 2025 | Louis Vlahos | Federal Budget
“State” of the Law A quick review of the cannabis landscape[i] reveals that most of the tax-related activity remains at the state level. At present, most states have decriminalized the use of cannabis products; it remains illegal in only a handful. Approximately half the states permit the recreational use of…
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Responding Timely to A “90-Day Letter” – Is It Jurisdictional?
September 11, 2025 | Louis Vlahos | Federal
Rules In the fictional world of John Wicks, the High Table enforces a strict code of conduct[ii] without which the lives of its inhabitants would mimic life in a Hobbesian state of nature.[iii] However, as dangerous and as rule-bound as life “under the Table” appears to be, it pales in…
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Gifting Qualified Small Business Stock – Can You “Stack” the Section 1202 Odds In Your Favor?
September 03, 2025 | Louis Vlahos | Business | Federal | Income Tax
C CorpImagine a closely held and growing start-up business (“Corp”) that was recently incorporated under state law and, so, is treated as a regular C corporation for purposes of the federal income tax.[i] Thus, Corp will pay income tax on its taxable income,[ii] and the losses generated in Corp’s first…
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The Uncharitable Treatment of Tax-Exempt Charities? Maybe, Maybe Not
August 13, 2025 | Louis Vlahos | Tax Exempt Organizations
In the tax world, when someone refers to a “charitable” organization, it is likely they are using the term in its generally accepted legal sense to include not-for-profit corporations or charitable trusts that are organized and operated “exclusively”[i] for religious, charitable,[ii] scientific, literary, educational, or other specified purposes.[iii] Provided such…
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The Enactment of OBBBA: It’s Time to Plan, Not Relax – “Winter is Coming”
July 31, 2025 | Louis Vlahos | Business | Federal
Not Long Ago In the months preceding the general election in 2024, the owners of many closely held businesses who had not yet given much thought to the disposition of their future estates, including their businesses,[i] decided they should meet with their attorneys and other advisers[ii] to see what steps…
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Drop & Swap Like-Kind Exchange Passes Muster in New York
July 23, 2025 | Louis Vlahos | Income Tax
Conformity New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation.[i] The reason typically given for such conformity is to simplify tax return preparation, improve compliance and enforcement, and aid in the interpretation of tax law provisions.[ii] The most significant example of…
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Closely Held Businesses and Their Owners Ask: What’s Big and Beautiful in the Recent Tax Law?
July 11, 2025 | Louis Vlahos | Federal
The “One Big Beautiful Bill Act” (the “Act”)[i] was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were introduced by the Tax Cuts and Jobs Act (P.L.…
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Taxes: An American Obsession?
July 08, 2025 | Louis Vlahos | Income Tax
Independence & Taxes Last week the United States celebrated the 249th anniversary of its declaration of independence from Great Britain.[i] In celebration of the occasion, President Trump signed into law the One Big Beautiful Act which, among other things, extended the tax cuts enacted during the first year of his first term…
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Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily
June 20, 2025 | Louis Vlahos | Loan
Related Party Loans If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related party loans”). However, in order for such a transaction to…
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