Installment Sale Notes Owned by S Corporations
When an S corporation sells its assets, often part of the purchase price is paid via a promissory note issued by the buyer. These promissory notes are part of…
The Spirit of Giving: NCBA’s New U.S. Tax Court Calendar Call Program
Of the three forums for judicial review of a federal tax dispute, only the Tax Court is a pre-payment forum, meaning a taxpayer can have a tax case heard by…
Unreimbursed Expenses of Employees and Partners
The 2017 Tax Cuts and Jobs Act included Section 67(h), which eliminated miscellaneous itemized deductions for tax years beginning after December 31, 2017. The…
Remembering Steve Horowitz, 1990-1991 Chair of the Tax Section
It is with deep sadness that we share the news of the passing of Steven (“Steve”) Horowitz, a former Chair of our Section (1990–1991) and a respected…
Recovering Costs and Attorney Fees From the IRS: The Qualified Offer Rules
The Qualified Offer rules are part of the broader framework for resolving federal tax disputes. As a general rule, taxpayers who prevail in disputes with the…
Welcome from the Tax Section Chair – Introducing Our 2025-2026 Leadership Team
Dear Tax Section Members, I am honored to serve as Chair of the North Carolina Bar Association Tax Section for the 2025-2026 year. Our Section continues to…
Publicly Traded Partnerships
Section 7704 provides a partnership is a publicly traded partnership if interests in the partnership are (1) traded on an established securities market or (2)…
What is a QSub?
As discussed in my February 2025 blog post Eligible S Corporation Shareholders, corporations generally cannot own the stock of S corporations, even if the…
Federal Income Tax Update
I. Wife Not Entitled to Any of Foreclosure Sales Proceeds of Husband’s Marital Home to Pay Husband’s Taxes Since Title was Solely in the Husband’s Name;…
Sale of Social Club Assets Upon Liquidation
Since 1916, Congress has exempted from income tax clubs formed to facilitate social interaction among their members. As a result, country clubs, hunting and…