The on-going COVID-19 pandemic has had a dramatic impact on the daily operations for the Internal Re...
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...
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...
Marijuana Dispensaries and the Federal Tax Trap
The marijuana industry has experienced a nationwide boom in the last five years. In 2013, the mariju...
I missed the deadline to file my tax return. Now what?
I missed the deadline to file my tax return. Now what? The deadline for individual taxpayers to file...
Does the Internal Revenue Service’s “willfulness” standard in Trust Fund Recovery Penalty cases include a “reasonable cause” defense?
The recent Sixth Circuit decision in Bibler v. U.S., 2018 WL 1911249, may mark an evolution of the d...
Recent Announcements: The IRS to End Offshore Voluntary Disclosure Program on September 28, 2018; FinCEN Increases FBAR Penalties to Reflect Inflation
Offshore Voluntary Disclosure Program Ends September 28, 2018 The IRS recently announced that it wil...
IRS Adopts The In-Person Approach
The Internal Revenue Service (IRS) had an interesting New Year’s resolution for 2018: more in-pers...
The IRS Adds Passport Revocation To Its Collections Arsenal
On January 16, 2018, the Internal Revenue Service (IRS) issued a press release emphasizing that taxp...
Reinstating Defaulted IRS Installment Agreements
Defaulted Installment Agreements The IRS expects taxpayers to pay all of their tax liabilities in fu...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the sixth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the fifth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
Divorce Decree Drafting Part 4
This is the fourth article in a four part series addressing frequently asked questions relating to p...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the fourth article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pr...
Notice of Right to a Collection Due Process Hearing – Is the IRS Trying to Hide the Ball?
The IRS must give a taxpayer written notice, sent by certified mail, at least 30 days before it take...