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...
IRS Adopts The In-Person Approach
The Internal Revenue Service (IRS) had an interesting New Year’s resolution for 2018: more in-pers...