For many taxpayers with multiple active business interests, the material participation test can be a...
What Happens If The Small Business Administration Tells Me Not To Pay My Business’s Employment Taxes?
For many business taxpayers who have Small Business Administration (SBA) financing that ultimately g...
Taking Advantage Of Expanded Penalty Relief
The recent enactment of the Tax Cut and Jobs Act (TCJA) put many individual taxpayers in a difficult...
Emphasizing Physical Injuries In Settlement Agreements
The United States Tax Court (Court) recently issued a decision highlighting, yet again, the importan...
Another Tax Blow To The Marijuana Industry
The marijuana industry remains in a difficult position when it comes to the federal tax implications...
Can The IRS Really Seize My Assets Without Telling Me First?
The Internal Revenue Service (IRS) can utilize its jeopardy levy function (i.e., taking a taxpayer...
Marijuana Dispensaries and the Federal Tax Trap
The marijuana industry has experienced a nationwide boom in the last five years. In 2013, the mariju...
Winning A Tax Battle, But Losing the Tax War
A recent U.S. Tax Court decision in Barker v. Comm’r of Internal Revenue, T.C. Memo. 2018-67 exemp...
Does the Internal Revenue Service’s “willfulness” standard in Trust Fund Recovery Penalty cases include a “reasonable cause” defense?
The recent Sixth Circuit decision in Bibler v. U.S., 2018 WL 1911249, may mark an evolution of the d...
Recent Announcements: The IRS to End Offshore Voluntary Disclosure Program on September 28, 2018; FinCEN Increases FBAR Penalties to Reflect Inflation
Offshore Voluntary Disclosure Program Ends September 28, 2018 The IRS recently announced that it wil...
IRS Adopts The In-Person Approach
The Internal Revenue Service (IRS) had an interesting New Year’s resolution for 2018: more in-pers...
The IRS Adds Passport Revocation To Its Collections Arsenal
On January 16, 2018, the Internal Revenue Service (IRS) issued a press release emphasizing that taxp...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the sixth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the fifth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the fourth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pr...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the third article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
FOIAs and GDPAs: How Requests for Information Can Help Resolve Cases with the IRS or MDR
This is the second article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pr...
FOIAs and GDPAs: How Requests for Information Can Help Resolve Cases with the IRS or MDR
This is the first article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
Explaining the Basics of the Quiet Disclosure of an FBAR
This is the sixth article in the Offshore Voluntary Disclosure Program (OVDP) Frequently Asked Quest...