David Burton
February 19, 2016
The U.S. Court of Federal Claims in a recent opinion, Bishop Hill Energy LLC v. United States, ruled against a discovery request made to the U.S. Treasury
Court of Federal Claims Fumbles Section 1603 Discovery Dispute
Tax Court Sheds Light on Counting Hours For the ‘Material Participation’ Exception to the Passive Activity Loss Rules
David Burton
January 22, 2016
David Burton examines the Tax Court’s recent analysis in Leland v. Commissioner, favoring a lawyer’s bid for exception from the passive activity loss rules
Tax Court Levels Taxpayer's Weak Theories in Rent Accrual Case
David Burton
September 28, 2015
This article was originally published in the September 28, 2015 edition of Tax Notes. The Tax Court’s recent decision in Stough v. Commissioner illustrates
IRS Private Letter Rulings Conflicted On Solar Tax Credits
David Burton
December 15, 2014
First Published in December 2014 in Solar Industry Magazine On Oct. 31, the U.S. Internal Revenue Service (IRS) released Private Letter Ruling (PLR) 201444
Project Finance Developer Fees Explained
David Burton
November 25, 2014
First published in Bloomberg BNA’s Daily Tax Report of November 25, 2014 In many renewable energy transactions, a ‘‘developer fee’’ is a critical feature—i
Missouri DOR Bungles Synthetic Lease
David Burton
August 11, 2014
David Burton discusses a recent ruling from the Missouri Department of Revenue that is intended to address the sales tax consequences of a synthetic lease
How Wind Developers Raise Equity In Public Markets
David Burton
May 31, 2014
Many wind developers regularly require additional capital infusion and keep their eyes peeled for opportunities to raise it. Three recent trends in public
All Drywall Systems Aren’t Created Equal Under MACRS
David Burton
May 15, 2014
David Burton examines a recent private letter ruling where the Internal Revenue Service held that ‘‘zip’’ drywall partition systems are depreciated faster
IRS Blesses TRAC Lease Securitization
David Burton
February 24, 2014
This article was first published by Bloomberg BNA Daily Tax Report on February 24, 2014 In Private Letter Ruling 201404007, released Jan. 24, the Internal
Salesman Penalized for ‘Placed in Service' Interpretation
David Burton
February 17, 2014
The Tax Court published an opinion that cautions taxpayers against being too innovative in their interpretation of this term of art.