This CLE program delves into six recent federal taxation cases that hold significant importance for tax attorneys. It offers valuable insights for business law attorneys navigating the complexities of federal taxation. By examining court opinions, participants will gain an understanding of how federal tax law evolves in contrast to legislative and regulatory processes.

The cases discussed in this program encompass various taxation topics including:

• Valuation of family-held S corporation stock for transfer taxation purposes.
• Limits on the IRS's authority to dictate income tax accounting methods.
• Taxpayer utilization of the substance over form doctrine and closely related step transaction doctrine.
• Classification of money manager gains as self-employment earnings subject to the 2010 3.8% Obamacare Medicare tax increase on high earners.
• Clarification on penalties for non-willful botched annual Foreign Bank Account Reports, imposing one $10,000 penalty per report rather than per offshore account.
• Analysis of penalties for willfully botched annual Foreign Bank Account Reports.