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Wagner Tax Law Blog

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Anticipating Tax Litigators…And the IRS (Part 2 of 2): Tax Strategy Tips

Since the COVID-19 pandemic, the Internal Revenue Service (IRS) has had a long backlog that, due in part to funding received in the Inflation Reduction Act of 2022, it only began to catch up on in mid-2023. In the meantime, the IRS’s backlogs and delays might have lulled taxpayers into a false sense of security. […]

Anticipating Tax Litigation… And the IRS (Part 1 of 2): Tax Filing and Maintenance Tips

Despite the relative rarity of an individual taxpayer’s file being brought to United States Tax Court or even audited, many taxpayers nevertheless fear the Internal Revenue Service (IRS) coming after them. This is not without good reason. Responding to an IRS audit alone can be time consuming and involves obtaining and compiling numerous documents. That […]

When Winning Isn’t “Prevailing”: Success in Bankruptcy Court Does Not Translate to Attorneys’ Fees

In June 2016, William Canada, Jr. took the Internal Revenue Service (IRS) to bankruptcy court and won. Mr. Canada successfully challenged the IRS’s claim for a $40 million penalty, pursuant to IRC §6707, for failing to report tax shelter transactions under IRC §6111. Per IRC §6707, the IRS imposes a penalty on anyone who fails […]