Experienced Tax Attorneys, Jeffrey R. Pittard and Harvey R. Poe, Successfully Obtain Summary Judgment Against the IRS
Lyndhurst, New Jersey, January 9, 2018 – Scarinci Hollenbeck is pleased to congratulate both Jeffrey R. Pittard and Harvey R. Poe on their recent victory against the IRS in Rafizadeh v. Commissioner, 150 TC 1 (2018). Marking the first Tax Court decision of 2018, the case considered whether the six-year statute of limitations set forth in IRC Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file FBAR forms from 2006 through 2008.
Results may vary depending on your particular facts and legal circumstances
IRC Section 6501(e)(1)(A)(ii) provides a six-year statute of limitations if a taxpayer omits from gross income amounts attributable to one or more assets with respect to information required under IRC Section 6038D. Despite the Government’s attempt to draw parallels between IRC Section 6038D and previously enacted statutes, the Tax Court ultimately determined that the statute being used to assess additional taxes from non-compliant taxpayers with foreign accounts could not be used for tax years prior to 2010 because there was no IRC Section 6038D filing requirement prior to that year. As a result of this ruling, the taxpayer ended up owing no additional taxes. Additionally, this ruling could potentially prevent the Government from collecting millions of dollars from other taxpayers in similar situations, making it a landmark decision for the US Tax Court.
“I’m proud of both Jeffrey and Harvey for their work on this particular case. The ruling is a testament to their proficiency and serves as a prime example of the expertise in Scarinci Hollenbeck’s Tax Law group. It is a win for our client as well as individuals finding themselves in similar situations involving the IRS,” said Frank Brunetti, Chair of Scarinci Hollenbeck’s Tax Law group.
A PDF of the full Tax Court opinion in Rafizadeh v. Commissioner, 150 TC 1 (2018) can be found here.
SH Partner Angela Turiano Named Director of Legislative Affairs for SHRM Princeton
Congratulations Angela Turiano on appointment as Director of Legislative Affairs for SHRM Princeton April 17, 2025 – Little Falls, NJ – Scarinci & Hollenbeck, LLC congratulates Partner Angela Turiano on her appointment as Director of Legislative Affairs for SHRM Princeton. Along with serving as a member of SHRM Princeton’s leadership team, Angela will monitor pending legislative, regulatory, […]
Brittany P. Tarabour Nominated as Three-Year Trustee of the Monmouth Bar Association
Congratulations Brittany P. Tarabour for Nomination as Three-Year Trustee of the Monmouth Bar Association Red Bank, NJ – April 9, 2025 – Scarinci & Hollenbeck, LLC proudly congratulates Brittany P. Tarabour on her nomination by the Monmouth Bar Association to serve as a Three-Year Trustee. Founded in 1908, the Monmouth Bar Association is dedicated to […]
Bloomberg Law Podcast Discusses Dua Lipa IP Victory with Ron Bienstock
Scarinci Hollenbeck Partner Ron Bienstock Featured on Bloomberg Law Podcast to Discuss Dua Lipa Copyright Infringement Lawsuits Little Falls, NJ – April 8, 2025 – Scarinci & Hollenbeck, LLC Partner and Chair of the firm’s Intellectual Property and Entertainment & Media departments Ronald S. Bienstock was recently featured on the Bloomberg Law podcast to discuss […]
NJ Super Lawyers Names Scarinci Hollenbeck Attorneys
Scarinci Hollenbeck Attorneys From Little Falls and Red Bank Named to 2025 New Jersey Super Lawyers List Little Falls, NJ – April 2, 2025 – Scarinci & Hollenbeck, LLC attorneys from both NJ offices were named to the 2025 New Jersey Super Lawyers and Rising Stars list. Each attorney was chosen in recognition of their […]
Dan McKillop to be Honored by Patriots Path Council of Scouting America
Little Falls, NJ – March 26, 2025 – Scarinci & Hollenbeck, LLC is pleased to announce that Daniel T. McKillop, Partner and Chair of the firm’s Cannabis Law practice group, will be recognized by the Patriots’ Path Council of Scouting America at the 2025 Legal Services Awards Reception, which will be held on Wednesday, April […]
Business Journal NJBIZ Names Ronald S. Bienstock and William C. Sullivan, Jr. Leaders in Law
Ronald S. Bienstock and William C. Sullivan, Jr. of Scarinci Hollenbeck Recognized as 2025 Leaders in Law by NJBIZ Little Falls, NJ – March 6, 2025 – One of New Jersey’s leading business journals, NJBIZ, has recognized Ronald S. Bienstock, Partner and Chair of the Intellectual Property Group, and William C. Sullivan, Jr., Partner and […]
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