Alston & Bird Tax Blog

U.S. Tax Court

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

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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

Borrowers Beware: Short Sales of Distressed Assets May Have Unfavorable Tax Consequences

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Beware of being shortsighted. Last week, our Federal Tax Group takes the long view for borrowers and their creditors seeking to use short sales to extricate themselves from nonrecourse debt. What is a short sale?Is the short sale one integrated transaction or two separate ones?Two federal court cases tell the story Read the full advisory here. [...]Read more