Justia Tax Law Opinion Summaries

MMC and the government agreed that MMC is entitled to an overpayment refund and further agree on the amount of that overpayment, but disagree on the interest rate to be applied. MMC argues that, despite being organized as a corporation under New York law, it should receive the benefit of the higher interest rate applicable to non‐corporations, because it is a nonprofit corporation and the word “corporation” in I.R.C. 6621(a)(1) should be construed to refer only to for‐profit corporations. The court held that I.R.C. 6621(a)(1)'s lower interest rate applies equally to for-profit corporations and nonprofit corporations such as MMC.  Accordingly, the court affirmed the judgment of the district court. View "Maimonides Medical Center v. United States" on Justia Law

Appellants challenged the magistrate judge's order denying a petition to quash an IRS summons. The court concluded that: (i) the attorney-client privilege was not waived by appellants’ provision of documents to a consortium of banks sharing a common legal interest in the tax treatment of a refinancing and corporate restructuring resulting from an ill-fated acquisition originally financed by the Consortium; and (ii) the work-product doctrine protects documents analyzing the tax treatment of the refinancing and restructuring prepared in anticipation of litigation with the IRS. Accordingly, the court vacated and remanded. View "Schaeffler v. United States" on Justia Law