This CLE program covers six federal taxation cases of recent vintage that are important for tax attorneys to commit to memory. Business law attorneys, who often find themselves in federal taxation deep water, can benefit from this Program because they will gain appreciation of the way federal tax law may change through court opinions in contrast to Congressional legislation and Department of Treasury tax regulation writing.

The cases together cover following taxation topics:

• Valuation of family held S corporation stock for transfer taxation purposes
• Limits on IRS power to dictate income tax accounting methods
• Taxpayer affirmative use of the substance over form doctrine and closely related step transaction doctrine
• Money manager gains broadly characterized as self-employment earnings subject to the 2010 3.8% Obamacare Medicare tax increase on high earners
• One $10,000 penalty per non-willfully botched annual Foreign Bank Account Report, not $10,000 per offshore account
• Tremendous penalty for willfully botched annual Foreign Bank Account Report