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Mississippi
CONTACT INFORMATION
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Name:
J. Paul Varner
Title:
Practice Group Leader-Tax Group
Company:
Butler, Snow, O'Mara, Stevens & Cannada, PLLC
Company Website:
Address:
1020 Highland Colony Parkway
Address:
Suite 1400
City:
Ridgeland
State:
Mississippi
Zip:
39157
Telephone:
601-985-4552
Fax:
601-985-4500
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RECENT CASES
Recent Cases:
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Fed Gift Tax Controversy. Representation of taxpayers in U.S. District Court to contest transferee liability for unpaid gift taxes.
- Fed Gift Tax Controversy. Representation of taxpayers before the IRS Appeals Division to defend discounts claimed in connection with the valuations of gifted interests in family limited partnerships.
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Fed Estate Tax Controversy. Representation of estate in the U.S. Tax Court to contest the disallowance of a charitable deduction for a post mortem grant of a conservation easement.
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Fed Income Tax Controversy. Representation of taxpayers before the IRS Appeals Division and the U. S. Tax Court to contest proposed assessments of income tax.
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State Tax Controversy. Representation of multi-state corporaton in Miss. Chancery Court involving the issue of how to apportion income earned from electronic commerce.
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State Tax Controversy. Representation of out-of-state individual taxpayers in multi-million dollar Miss. income tax assessment; taxpayers could not post jurisdictional bond, so relief was secured in TRO action in Miss. Chancery Court resulting in favorable settlement for taxpayers of approximately 25% of original assessment..
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State Tax Controversy. Representation of Fortune 500 company in multi-million dollar income tax assessment and refund action in Miss. Chancery Court resulting in $4,000,000 refund (issue was whether gain on sals of business was business income or nonbusiness income under UDITPA).
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State Tax Controversy. Representation of multi-state corporation seeking refund of state use taxes pursuant to exemption based on payment of sales tax to another state on the same transactionn Weeks Dredging & Contracting, Inc. v. MS State Tax Commission, 521 So. 2d 884 (Miss. 1988).
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State Tax Controversy. Representation of multi-state corporation in Miss. Chancery Court contesting the disallowance of deductions for premiums paid to captive insurance company.
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Tax Deferred Exchanges. Representation of numerous taxpayers in structuring and documenting forward and reverse like kind exchanges of real property.
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Corporate Reorganizations. Representation of numerous corporations in structuring acquisitive and divisive tax-free reorganizations.
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Private letter Rulings. Representation of numerous taxpayers to successfully obtain private letter rulings on various issues from both the IRS and the Miss. State Tax Commission.
SPEECHES & PUBLICATIONS
Speeches & Publications:
"Summary of First Quarter 2008 Developments in Mississippi Tax Law,"Mississippi Tax Bulletin, April 2008
“Summary of 2007 Developments in Mississippi Tax Law,” Mississippi Tax Bulletin, February 2008.
"Two Recent Mississippi Tax Cases,” Mississippi Tax Bulletin, October 2007.
“Legislative Developments,” Mississippi Tax Bulletin, June 2007.
“Unconstitutional Corporate Tax Statutes,” Mississippi Tax Bulletin, October 2006.
“Mississippi Income Tax Developments,” Mississippi Tax Bulletin, July 2006.


