The fight over who meets the definition of a “real estate professional” is not a new one. Fortun...
Can You Remotely Satisfy The Material Participation Test?
For many taxpayers with multiple active business interests, the material participation test can be a...
Emphasizing Physical Injuries In Settlement Agreements
The United States Tax Court (Court) recently issued a decision highlighting, yet again, the importan...
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�...
The IRS’s Expanding Definition Of Willfulness In FBAR Cases
The Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (Program) has eleme...