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.
Feedspot Names Government & Law Blog One of the Top Public Law Blogs
FeedSpot Recognizes Donald Scarinci’s Government & Law Blog One of the Top 20 Public Law Blogs Little Falls, NJ – May 22, 2025 – Scarinci Hollenbeck, LLC is honored to share that Managing Partner Donald Scarinci’s Government & Law blog has been listed by FeedSpot.com as one of the “20 Best Public Law Blogs and […]
Scarinci Hollenbeck's Ron Bienstock Speaks at 100th Bomb Group's 2025 Reunion
SH Partner and 100th Bomb Group Foundation Legal Counsel Discussed The Nuremberg Trials and the Law May 21, 2025 – Little Falls, NJ – Scarinci & Hollenbeck, LLC is proud to share that partner Ronald S. “Ron” Bienstock recently spoke at the 100th Bomb Group Biennial Reunion, held May 15-18, 2025, in New Orleans. The […]
FeedSpot Names Donald Scarinci’s Constitutional Law Reporter One of the Top 100 Legal Blogs
Little Falls, NJ – May 1, 2025 – Scarinci Hollenbeck, LLC is proud to share that Managing Partner Donald Scarinci’s Constitutional Law Reporter blog has been listed by FeedSpot.com as one of the “Top 100 Legal Blogs.” No Aspect of the advertisement has been approved by the Supreme Court. Feedspot, a content reader that curates websites of […]
FeedSpot Names Donald Scarinci’s Government & Law Blog One of the Top 80 New Jersey Blogs
Little Falls, NJ – May 1, 2025 – Scarinci Hollenbeck, LLC is proud to share that Managing Partner Donald Scarinci’s Government & Law blog has been listed by FeedSpot.com as one of the “80 Best New Jersey Blogs and Websites in 2025.” *No Aspect of the advertisement has been approved by the Supreme Court of New […]
Nathanya G. Simon Named to ROI-NJ Influencers "Women in Business" 2025 List
Scarinci Hollenbeck Partner Nathanya G. Simon named by ROI-NJ to the “ROI Influencers: Women in Business” list for fourth consecutive year Scarinci Hollenbeck Partner Nathanya G. Simon has been named by ROI-NJ to the “ROI Influencers: Women in Business” list for 2025. After four decades of practice, Nathanya’s pioneering influence in the field of special […]
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, […]
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