Kamyar Mehdiyoun

/Kamyar Mehdiyoun
Kamyar Mehdiyoun

Kamyar Mehdiyoun, holds a Master of Law (LL.M.) degree in taxation from Georgetown University Law Center and focuses his practice on tax law. In 2003, he received the Award for Excellence in Tax Practice and Procedure from Georgetown. He also holds a Certificate in Employee Benefits Law from Georgetown. He graduated from Boston College Law School with a Juris Doctor (J.D.) degree in 2000.

Husband’s Innocent Spouse Claim – Tax Article

Innocent Spouse Claim Had Merit

Tax Court Rules Husband’s Innocent Spouse Claim Had Merit.

After the IRS audited a jointly filed tax return, it found that $15,000 in retirement distributions weren’t reported and assessed additional taxes. The husband filed an innocent spouse claim arguing that he didn’t have actual knowledge about the distribution and that his ex-wife had deceived him by not telling him about the distributions from her retirement account. The court held that even though the husband should have known about the distribution, the absence of actual knowledge meant that his innocent spouse relief claim should be accepted.

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Ranching Operation Taxes – Hobby or Business

Taxes – Hobby or Business

Under the Tax Code Taxpayer’s Ranching Operations Constituted a ‘Trade or Business’ and Not a Hobby.

Taxpayer was an economics professor for approximately 40 years. He also owned an economic consulting firm. In addition to his regular job as an economist, he also ran a ranch and cattle operation in Texas. Taxpayer’s ranching operation incurred large losses in 2007 to 2010 tax years. The IRS issued a notice of deficiency for tax years 2007, 2008 and 2009 because in the IRS’s view the livestock operation wasn’t engaged in for profit. According to the IRS,

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CA District Court – United States v Sanmina Corp

Advice of Tax Attorney Upheld by CA Court

California District Court upholds confidentiality of advice by tax attorney. United States v. Sanmina Corp

In May 2015, a district court in California ruled that the IRS could not obtain a corporate taxpayer’s records related to tax advice prepared by the taxpayer’s in-house tax lawyers. United States v. Sanmina Corp., No. 5:15-cv-00092 (2015 U.S. Dist. LEXIS 66123). The court held that the records were protected by the attorney-client confidentiality rules and that the IRS had not shown that the taxpayer had waived the attorney-client privilege.

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