On April 2, 2024, Senate File (SF) 4742, as a companion to House File (HF) 4934, was subject to a he...
Government Transparency: Commissioner of Revenue to be Bound by Court Decisions
On Thursday, March 21, 2024, the Minnesota Senate Tax Committee had a hearing regarding Chair Ann Re...
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...
IRS Acted “Against Equity or Good Conscience” to Deny Hardship Due to Depression
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...