Two Idaho software entrepreneurs (and brothers) sued the IRS to fight adjustments that increased their tax bills by more than $11 million each.
David Boren and Michael Boren, the founders of the software-as-a-service company Clearwater Advisors, filed a petition in tax court in late November, saying the adjustments were improper and that they had “substantial authority and reasonable basis” to submit them this way.
On both returns, the IRS disallowed $4.91 million in claimed non-passive losses and non-passive income from flow-through sources in 2020. Deficiency notices totaling $9.26 million, plus $1.85 million in fines, have been issued. It also increased the net income tax by…