QSBS Case Law

IRS Guidance Methods

IRS’s Different Guidance Forms There are different forms of communication the Chief Counsel can use in order to relay tax guidance to individuals. These forms of communication, which can be interpreted in a highest to lowest authoritative level, can be: RegulationsIssued by the Internal Revenue Service (IRS) and Treasury … Read More

QSBS Court Ruling: Owen v. Commissioner of Internal Revenue-Why is an “active business” requirement under (§1202(e)) important when applying a §1045?

United States Tax Court, Nos. 930–07, 1384–07, 13303–07, 29011–08, 29090–08, January 19, 2012 KEY QSBS TAKEAWAY(S): In Owen v. Commissioner, the taxpayer met the 60–day requirement of section 1045(a)(1) because the stock purchase agreement transaction was signed on June 17, 2002, and the sold Family First Companies shares--amounting to … Read More