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...
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...
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...
Can You Remotely Satisfy The Material Participation Test?
For many taxpayers with multiple active business interests, the material participation test can be a...
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...
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...