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...
IRS To Increase Focus On Delinquent-Filed Returns
The Internal Revenue Service (IRS) announced, in a recent Information Release and Fact Sheet, that i...
Proving ‘Material Participation’ In Today’s Digital Age
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...
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...
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�...
How Does an Employer Comply with an IRS Wage Levy?
When an individual has outstanding federal tax liabilities, the Internal Revenue Service (IRS) has a...
The IRS’s Expanding Definition Of Willfulness In FBAR Cases
The Internal Revenue Service’s (IRS’s) Offshore Voluntary Disclosure Program (Program) has eleme...