TaxSlaw

It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s over-regulation of business and, probably most of all, its…
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Exercised Appraisal Rights? Deferred Payment of Contingent Value? Don’t Forget Imputed Interest
November 17, 2025 | Louis Vlahos | Real Estate

An Extension of Credit When one person lends money to another, the lender expects the borrower to repay the loan by an agreed-upon time. In order to compensate the lender for the borrower’s use of the lender’s money (the loan proceeds), the lender will require the borrower – at least…
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Change May Be Good The enactment earlier this year of the One Big Beautiful Bill Act (the “Act”)[i] generated a fair amount of excitement in the business community.[ii] If one had to identify a single provision of the Act in which the owners and prospective owners of start-up and emerging…
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Reallocating the Payment of Income Between Controlled Taxpayers – What if the Payment is Prohibited?
October 22, 2025 | Louis Vlahos | Income Tax

Suspect Transactions (?) It is axiomatic that a transaction between related businesses – i.e., businesses that are owned or controlled directly or indirectly by the same interests (a “controlled group”) – will generally be subject to heightened scrutiny by the IRS to ensure the transaction was not undertaken or structured…
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Another Setback for Monetized Installment Sales?
October 09, 2025 | Louis Vlahos | Federal | Income Tax

Abusive Arrangements As part of its enforcement efforts, the IRS annually identifies what it describes as potentially abusive transactions that taxpayers should avoid.[i] According to the agency, some of these transactions are focused on more complex arrangements that promoters market to higher-income individuals. The IRS has stated that such arrangements…
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Visiting the Sins of the Tax Preparer Upon the Taxpayer? The Fraud Exception to the Limitations Period on Assessment
October 01, 2025 | Louis Vlahos | Federal

Determining Tax Deficiencies As we discussed a few weeks ago,[i] the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection function, the agency may examine a taxpayer’s books, accounts, financial and other…
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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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