Massachusetts District Court Explores the United States’ Burden of Proof Argument on Deductions of Government Settlements
Brian W. Kittle,Thomas Kittle-Kamp, May 22, 2013
On May 9, 2013, the US District Court of Massachusetts issued a Memorandum and Order in Fresenius Medical Care Holding, Inc. v. United States, involving federal income tax deductions related to the settlement of several government Federal False Claims Act (FCA) claims. The court’s Memorandum...

Rare Victory for Corporate Taxpayers Provides Insight to In-House Tax Departments Regarding Employee Privacy and Privileged Documents
Charles P. Hurley,Brian W. Kittle,Nicole M. Reuling,Joel V. Williamson, October 12, 2012
In a rare victory for corporate taxpayers involved in IRS summons enforcement proceedings, the US District Court for the Northern District of Ohio issued three rulings on August 15, 2012, that recognize the privileged status of certain types of corporate taxpayer records when those records are...