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...
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...
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...
FOIAs and GDPAs: How Requests for Information Can Help Practitioners Resolve Cases with the IRS or DOR
This is the third article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pra...
FOIAs and GDPAs: How Requests for Information Can Help Resolve Cases with the IRS or MDR
This is the second article in the Freedom Of Information Act Requests (FOIAs) and Government Data Pr...