Selected Recent Federal Income Tax Developments

Pages 1-2 (#A2): In Straight the Tax Court penalized the I.R.S. $5,000 because the revenue agent made changes to her report and later testified inconsistently about the matter, thereby causing the taxpayer to incur extra attorney's fees.Fees were not awarded under §7430, presumably because the taxpayer did not prevail in the case.What sanctions are available in these circumstances?ii.Page 23 (#C2):Estate of Davis is a valuation case, and you told us in prior years that valuation cases and other factual cases are typically memorandum opinions.What was special about this one that causes you to characterize it as a published opinion?Note, also, the Eisenberg case at #C3.II:./ Page 25 (#D6): Last year we discussed Winn, which was withdrawn simultaneously with the release of the opinion in Mel T. Nelson.Can you say anything more about the change of position?Iv. Page 55 (#D2): Will the legislative solution to the unfairness of Elgart avoid the large number of cases involving motions to dismiss for lack ofjurisdiction whenever a petition is filed a day or two late? V.Page 60 (#15a): What changes can we expect to see in the Tax Court as a result of the new burden of proof shift? vi.Page 60 (#F15d): What changes can we expect to see in the Tax Court as a result of the increase in the amount from $10,000 to $50,000 for cases to be eligible for the simplified procedure ("S") election?vii.Pages 61-62 (#F16): What changes can we expect to see in the Tax Court as a result of the opinion of the Sixth Circuit in Estate of Mueller?