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...
What’s in a Name?: The ABA Attempts to Define “Cryptocurrency”
Until relatively recently, the number of individuals who bought and sold cryptocurrencies (crypto) a...
Is The IRS Going to the Moon?: President Biden’s Executive Order on Digital Assets
On March 9, 2022, President Biden signed an executive order setting out his administration’s strat...
A Qualified Offer the IRS Could Refuse
The Internal Revenue Service (IRS), like any self-respecting bureaucracy, sometimes makes mistakes. ...
A Sordid Tale of Donkeys and Horses: Tax Court Style – Part One
The following tale is the first in a two part series relating to a couple of recent decisions from t...
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...
Can Cleaners Be Treated As Independent Contractors?
The proper classification of workers is a decision that is critical to the success or failure of man...
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...
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...
Proving ‘Material Participation’ In Today’s Digital Age
The fight over who meets the definition of a “real estate professional” is not a new one. Fortun...
Can You Remotely Satisfy The Material Participation Test?
For many taxpayers with multiple active business interests, the material participation test can be a...