Jeb Burton

At our recent Annual Conference in Amsterdam, Sept 2023, we had the pleasure of awarding Jeb gold member status as recognition for their ongoing commitment and hard work within the IR Global network. This is a prestigious honour bestowed by IR Global upon members who we consider have made a substantial contribution to the development…

Normally, a typed (nonholographic) will must be signed by at least two persons who witnessed the testator’s signature of the will or the testator’s acknowledgment of the document as the testator’s will. The law requiring these formalities was amended in 2008 through the changes to Probate Code § 6110(c)(2) to provide an exception allowing a…

A supplemental (or special) needs trust is a means to assist a beneficiary with a disability while preserving the beneficiary’s eligibility for public benefits. As of now there is “little legal interpretation of and commentary on special needs trusts.” A California case, McGee v. State Department of Health Care Services, attempted to remedy this deficiency…

The Inspector General for the IRS (TIGTA) reviewed the examination practices of the Large Business and International (LB&I) Division from fiscal year (FY) 2017 through 2021. LB&I’s examinations are divided between businesses and individual international taxpayers. About 67% of LB&I’s examinations were conducted on individual taxpayers totaling 63,420 audits. Of these, 90% of the taxpayers…

The statutory interpretation canon dictating that exemptions from taxation are strictly construed against the taxpayer is frequently used by the IRS in order to enforce their own interpretation of the tax code on all those subject to taxation. Bibeau v. Commissioner, T.C. Memo. 2023-66, recently demonstrated this canon’s interaction with another that would instead favor…

In Fuentes v. Empire Nissan, Inc., it appears that Nissan attempted to test the limits of the use of small print in contracts.[1] The plaintiff was a discharged employee who sued in a superior court, arguing that the arbitration agreement in the contract that they had signed with Nissan was unconscionable. At first, the California…

The Supreme Court opined about a canine chew toy in Jack Daniel’s Properties, Inc. v. VIP Products LLC. The defendant sells dog toys parodying Jack Daniel’s beverage. The toys are similarly shaped (but of different material) and are called “Bad Spaniels,” with a descriptive label of “The Old No. 2 On Your Tennessee Carpet” instead…

The IRS told a tale: A Taxpayer creates a secure Business Online Account at IRS.gov and lets us know which communications methods they prefer – email, paper mail or phone. The taxpayer selects email. They later receive an email explaining tax credits and deductions for which they may be eligible. Their online account gives them…