On October 24, 2024, Commissioner Daniel Werfel announced that the Internal Revenue Service (IRS) wo...
Treasury and Internal Revenue Service Crack Down on Related-Party Basis Shifting
In June of 2024, the Internal Revenue Service (IRS) issued guidance attempting to address the percei...
Internal Revenue Service Plans Dozens of Corporate Jet Audits
On February 21, 2024, the Internal Revenue Service (IRS) announced that it plans to begin dozens of ...
The Challenges for Art Donation (Part 2 of 3): Economic Substance
As discussed in part one of this series on art donations, a taxpayer who wishes to receive a tax ded...
Employee Retention Credit Voluntary Disclosure Program Ends March 22, 2024
The Employee Retention Credit (ERC) is a refundable tax credit for certain eligible business and tax...
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 ...
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 Co...
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 wo...
What’s in a Name?: The ABA Attempts to Define “Cryptocurrency”
Until relatively recently, the number of individuals who bought and sold cryptocurrencies (crypto) a...
A Qualified Offer the IRS Could Refuse
The Internal Revenue Service (IRS), like any self-respecting bureaucracy, sometimes makes mistakes. ...
A Sordid Tale of Donkeys and Horses: Tax Court Style – Part One
The following tale is the first in a two part series relating to a couple of recent decisions from t...
Three Things – Ask A Tax Attorney
Recently, I wrote an article for the Hennepin County Lawyer addressing some of the kinds of tax ques...
Tax Questions Every Solo And Small Firm Lawyer Should Be Able To Answer
Appearing in the October of 2021 issue of ALI CLE’s The Practical Lawyer is an article by Kathleen...
IRS Issues Guidance Regarding Levy Actions Involving Restaurant Revitalization Fund
The American Rescue Plan Act established the Restaurant Revitalization Fund (RRF) to provide support...
IRS Prevails In Pursuing An Alter Ego Assessment
Corporate income taxes are generally the responsibility of the corporation and not the individuals t...
IRS Offers Additional Taxpayer Relief in Response to Covid-19
On March 25, 2020, the Internal Revenue Service (IRS) released guidance related to its “People Fir...
What To Do if I Can’t Pay My Taxes by the IRS’s July 15 Tax Deadline
In light of the current Covid-19 ...
Can Cleaners Be Treated As Independent Contractors?
The proper classification of workers is a decision that is critical to the success or failure of man...
How to Appeal the Trust Fund Recovery Penalty After the Appeal Period has Passed: Offer in Compromise, Doubt as to Liability
There are many reasons businesses fall behind on paying their federal tax liabilities. Falling behin...
Taking Advantage Of Expanded Penalty Relief
The recent enactment of the Tax Cut and Jobs Act (TCJA) put many individual taxpayers in a difficult...