Federal Taxation

During 1995, as in past years, the Eleventh Circuit considered several procedural issues. The procedural issues decided in 1995 involved refund claims, tax liens, and litigation fees. As to substantive tax issues, the court affirmed the taxpayer-favorable Tax Court decision in Estate of Hubert v. Commissioner. The estate tax issue involved, however, is a controversial one, and the Sixth and Federal Circuit Courts of Appeals have previously reached a contrary conclusion.