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George Abney

About George Abney

George Abney is a partner on the firm’s Tax Controversy Team, whose practice focuses on civil and criminal tax controversy matters. George has significant trial and appellate experience gained from years as a federal prosecutor with the Tax Division of the U.S. Department of Justice in Washington, D.C., and as an assistant U.S. attorney in the Northern District of Florida.

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When Is a Deadline Not a Deadline? The Supreme Court Intends to Decide

November 1, 2021 By Laura Gavioli and George Abney

Our Federal Tax Group investigates why the U.S. Supreme Court may use a Tax Court case to decide whether a statutory deadline is set in stone or if a court can permit an untimely suit to proceed through equitable tolling. The Tax Court ruled that a statutory deadline is jurisdictional; Eighth Circuit agreesTaxpayer access to the Tax Court is at stakeThe COVID-19 pandemic – and its attendant delays – has thrown the issue into the spotlight Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Equitable tolling, IRS, Taxpayers, U.S. Tax Court

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

May 24, 2021 By George Abney, Laura Gavioli and Eli McCrain

Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action. CIS Services v. IRS narrows the reach of the Anti-Injunction ActThree features of Notice 2016-66 helped the Court overturn lower courts’ rulings in favor of the IRSThe IRS’s rule-making process now open to more Administrative Procedure Act challenges Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Administrative Procedure Act, AIA, Anti-Injunction Act, CIS Services, IRS, Notice 2016-66, SCOTUS, Supreme Court

Splitting the Difference: IRS Applies Exempt Organization Excise Tax to Split-Dollar Life Insurance Policies

July 9, 2020 By George Abney, Mark Williamson, Daniel Reach and April McLeod

Our Federal Tax Group delves into proposed Treasury regulations addressing exempt organizations’ below-market loans used to pay for split-dollar life insurance premiums. Split-dollar life insurance loans became even more beneficial after the TCJA added a new excise tax on exempt organizations under Section 4960Imputed income from below-market split-dollar life insurance loans must be included in Section 4960 calculationImputed income can be avoided by charging interest at the historically low applicable federal rate Read the full advisory here. To learn more about our exempt organization [...]Read more

Filed Under: Exempt Organization, Federal Tax Advisory Tagged With: AFR, applicable federal rate, below-market loans, excise tax, Section 4960, Section 7872, split-dollar, TCJA, Treasury

Proposed Treasury Regulations Clarify UBTI “Silo” Rule

May 20, 2020 By Clay Littlefield, Daniel Reach, George Abney and Mark Williamson

Nearly two years ago, in the wake of the Tax Cuts and Jobs Act, the IRS issued interim guidance on the unrelated business taxable income (UBTI) “silo” rules. Our International Tax Group examines recently released proposed Treasury Regulations that largely follow, and partially expand, that guidance. Special rules for investment activities, including “qualified partnership interests”Interactions with net operating loss rules, as modified by the TCJA and the CARES ActEffects on Subpart F, GILTI, and other rules For the full advisory, click here. [...]Read more

Filed Under: Uncategorized Tagged With: CARES Act, Controlled Entities, Deb-financed properties, GILTI, IRS, NAICS, NOLs, partnership, QPI, S Corp, Schedule K-1, Subpart F, TCJA, Treasury, UDFI

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