Experienced Tax Attorneys, Jeffrey R. Pittard and Harvey R. Poe, Successfully Obtain Summary Judgment Against the IRS
Lyndhurst, New Jersey, January 9, 2018 – Scarinci Hollenbeck is pleased to congratulate both Jeffrey R. Pittard and Harvey R. Poe on their recent victory against the IRS in Rafizadeh v. Commissioner, 150 TC 1 (2018). Marking the first Tax Court decision of 2018, the case considered whether the six-year statute of limitations set forth in IRC Section 6501(e)(1)(A)(ii) applied to a taxpayer who failed to file FBAR forms from 2006 through 2008.
Results may vary depending on your particular facts and legal circumstances
IRC Section 6501(e)(1)(A)(ii) provides a six-year statute of limitations if a taxpayer omits from gross income amounts attributable to one or more assets with respect to information required under IRC Section 6038D. Despite the Government’s attempt to draw parallels between IRC Section 6038D and previously enacted statutes, the Tax Court ultimately determined that the statute being used to assess additional taxes from non-compliant taxpayers with foreign accounts could not be used for tax years prior to 2010 because there was no IRC Section 6038D filing requirement prior to that year. As a result of this ruling, the taxpayer ended up owing no additional taxes. Additionally, this ruling could potentially prevent the Government from collecting millions of dollars from other taxpayers in similar situations, making it a landmark decision for the US Tax Court.
“I’m proud of both Jeffrey and Harvey for their work on this particular case. The ruling is a testament to their proficiency and serves as a prime example of the expertise in Scarinci Hollenbeck’s Tax Law group. It is a win for our client as well as individuals finding themselves in similar situations involving the IRS,” said Frank Brunetti, Chair of Scarinci Hollenbeck’s Tax Law group.
A PDF of the full Tax Court opinion in Rafizadeh v. Commissioner, 150 TC 1 (2018) can be found here.
Scarinci Hollenbeck Attorneys Named to New Jersey Super Lawyers 2026
Scarinci Hollenbeck Attorneys Named to New Jersey Super Lawyers 2026 and Rising Stars Lists Scarinci Hollenbeck is pleased to announce that several of its attorneys have been selected for inclusion in the New Jersey Super Lawyers 2026 and Rising Stars lists. The annual recognition highlights attorneys who have attained a high degree of peer recognition […]
Donald M. Pepe and Donald Scarinci Named to 2026 ROI-NJ Influencers: Law List
ROI-NJ Continues to Feature Donald Scarinci and Donald M. Pepe on Annual Influencers in Law List Donald M. Pepe and Donald Scarinci of Scarinci Hollenbeck have once again been named to ROI-NJ’s 2026 Influencers: Law List, recognizing attorneys who continue to shape New Jersey’s legal and business landscape. The annual list highlights legal professionals whose […]
Monmouth Bar Golden Gala Honors Two Scarinci Hollenbeck Attorneys
Scarinci Hollenbeck is proud to share that two highly acclaimed retired judges who now serve as Of Counsel to the firm, Hon. Ira E. Kreizman, J.S.C. and Hon. Ronald Lee Reisner, J.S.C., will be honored at the Monmouth Bar Association’s Golden Gala. The event recognizes members of the Monmouth Bar Association who have practiced law […]
NJ Real Estate Attorney Joe DeMarco Named in 2026 NJBIZ Leaders in Law List
Scarinci Hollenbeck is pleased to announce that NJ Real Estate Partner, Joe DeMarco, has been named a 2026 Leaders in Law Award Honoree by NJBIZ in the Real Estate: Construction, Environmental, Leasing category. The NJBIZ Leaders in Law program recognizes attorneys and general counsels whose professional accomplishments, leadership, and service to their communities demonstrate a […]
John M. Scagnelli Re-Elected to LSRPA Board of Trustees
Scarinci Hollenbeck is pleased to announce that Partner John M. Scagnelli has been re-elected to serve on the Board of Trustees of the Licensed Site Remediation Professionals Association (LSRPA) for an additional two-year term. LSRPA is the statewide professional organization representing New Jersey’s Licensed Site Remediation Professionals (LSRPs), playing a central role in advancing environmental […]
Robert E. Levy Re-Certified as Civil Trial Attorney by the Supreme Court of New Jersey
Scarinci Hollenbeck is pleased to announce that Robert E. Levy has been re-certified as a Certified Civil Trial Attorney by the Supreme Court of New Jersey. This re-certification, combined with Levy’s existing designation as a Certified Criminal Trial Attorney, places him among less than one percent of all certified attorneys in New Jersey to hold […]
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