On April 20, 2017, the United States Tax Court (Court) held in favor the petitioners, John C. Trimme...
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...
Is The IRS Going to the Moon?: President Biden’s Executive Order on Digital Assets
On March 9, 2022, President Biden signed an executive order setting out his administration’s strat...
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 Two
On December 16, 2021, the United States Tax Court issued a memorandum opinion in the case of Skolnic...
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...
Split In The 5th Circuit Muddies The FBAR Waters
There has been a potentially landscape-altering decision out of the Fifth Circuit Court of Appeals (...
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 Ratchets Up Efforts To Pursue Noncompliant Taxpayers
The United States Department of Treasury (the Treasury) issued “The American Families Plan Tax Com...
IRS Prevails In Pursuing An Alter Ego Assessment
Corporate income taxes are generally the responsibility of the corporation and not the individuals t...
IRS Provides Additional Guidance To Passport Revocation Process
In January of 2018, the Internal Revenue Service (IRS) issued a press release advising delinquent ta...
Can You Still Obtain A Lien Release Or Certificate Of Discharge In The Middle Of A Pandemic?
The on-going COVID-19 pandemic has had a dramatic impact on the daily operations for the Internal Re...
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...
Not Exactly Bona Fide: Avoiding The Faulty Loan Trap
It is not uncommon for small businesses to rely on friends and family for loans to assist the busine...
IRS Releases People First Initiative FAQs
On March 25, 2020, the Internal Revenue Service (IRS) announced its “People First Initiative,” a...
Death Is No Defense When It Comes To FBAR Penalties
People often joke that the only certainties in life are death and taxes. Well, it turns out that, wh...
IRS Expands Operations And Issues Additional Guidance In Response to Ever-Changing Pandemic Environment
On April 24, 2020, the Internal Revenue Service (IRS) issued an internal memo advising its employees...
Working With Taxing Authorities During The Coronavirus Pandemic
The recently imposed social distancing measures that are critical and essential to our nation’s ba...