Overview of the Fifth Circuit’s Decision
The United States Court of Appeals for the Fifth Circuit (“Fifth Circuit”) handed certain partners in limited partnerships within its jurisdiction a huge win regarding self-employment tax. In Sirius Solutions, L.L.L.P. v. Commissioner,[1] a divided Court of Appeals held that a limited partner for purposes of the
A new Supreme Court decision creates potential traps for the unwary and gives the Internal Revenue Service (“IRS”) nationwide power to leave a taxpayer without a remedy to contest certain collection actions. Importantly, while a Collection Due Process (“CDP”) action is pending, taxpayers should ensure to the extent possible that no refunds are generated for