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...
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...