Two Idaho software entrepreneurs—and brothers—sued the IRS to fight adjustments that increased their tax bills by over $11 million each.
David Boren and Michael Boren, who founded software-as-a-service firm Clearwater Advisors, petitioned the Tax Court in late November saying the adjustments were improper and that they had “substantial authority and reasonable cause” for filing them as they did.
On both returns, the IRS disallowed $4.91 million of claimed nonpassive loss and nonpassive income from flow-through sources in 2020. It issued notices of deficiency of $9.26 million, plus $1.85 million in penalties. It also increased the net investment income tax by ...
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