Ariana Fazel Wallizada

In a recent taxpayer win, the United States District Court for the District of Minnesota granted summary judgment in an $11.5 million refund claim brought by the Mayo Clinic (“Mayo”) on the basis that certain Treasury...more The new Tax Cuts and Jobs Act has changed certain provisions of the Internal Revenue Code (the Code) pertaining to the deductibility of amounts paid to Government entities for violations of law. Section 162(a) of the Code has...more In a July 13, 2017 opinion, the United States Tax Court in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner refused to follow the long-held IRS position found in Revenue Ruling 91-32 (“the “Revenue...more Do Not Sell or Share My Personal Information Cookie Preferences