On April 20, 2017, the United States Tax Court (Court) held in favor the petitioners, John C. Trimme...
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 (...
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 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...
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...
IRS To Increase Focus On Delinquent-Filed Returns
The Internal Revenue Service (IRS) announced, in a recent Information Release and Fact Sheet, that i...
What Happens If The Small Business Administration Tells Me Not To Pay My Business’s Employment Taxes?
For many business taxpayers who have Small Business Administration (SBA) financing that ultimately g...
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�...
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...
Winning A Tax Battle, But Losing the Tax War
A recent U.S. Tax Court decision in Barker v. Comm’r of Internal Revenue, T.C. Memo. 2018-67 exemp...
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...
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...