Tag Archives: AT

Attorneys' Fee Awards

Attorneys' Fee Awards

Description and Definition of Attorneys' Fee Awards

If you litigate with the IRS in Tax Court or another federal court and win and you can show that the IRS's position was unreasonable you may be entitled to a certain amount for attorneys' fees and other litigation expenses.

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At-risk Rules

At-risk Rules

About At-risk Rules:

See in the American Legal Encyclopedia

Description and Definition of At-Risk Rules

The At-Risk Rules limit your loss deductions to the actual amount you are at risk for, including promissory notes on which you are personally liable. There is an exception for real estate which treats certain non-recourse commercial loans as amounts “at risk”.

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Attorney-at-law

Attorney-at-law

Attorney-at-law means:
a person admitted to practice law in a jurisdiction, authorized to perform both civil and criminal legal functions for clients. These functions include drafting legal documents, giving legal advice, and representing clients before courts, administrative agencies, boards, and other bodies.

Attribution Rules

Attribution Rules

Attribution Rules means:
rules that create ownership by attributing stock to one party even though the shares are legally owned by another party; often called constructive ownership of stock. See also related parties. Rule 1. Stock directly or indirectly owned by or for a corporation, partnership, estate, or trust is considered owned by or for its shareholders, partners, or beneficiaries.

Rule 2. An individual is considered to own stock that is directly or indirectly owned by or for his or her family. Family includes only brothers, sisters, half-brothers, half-sisters, spouses, ancestors, and lineal descendants.

Rule 3. An individual owning any stock in a corporation is considered to own the stock that is directly or indirectly owned by his or her partner.

Rule 4. Stock constructively owned by a person under Rule 1 is treated as actually owned by that person for the purposes of applying Rules 2 and 3. Stock constructively owned by a person under Rule 2 or 3 is not treated as owned by that person for again applying Rule 2 or 3. Former IRC (check if this IRC provision is current here) §§267(c), 318, and 544(a).