In Jewell v. U.S., Taxpayer Sam Jewell was the subject of an IRS investigation which resulted in third party summonses being issued to banks located in both the Eastern and Western Districts of Oklahoma. Mr. Jewell challenged...more
The IRS recently filed a motion to dismiss class action claims brought by Tea Party groups. In NorCal Tea Party Patriots, et. al. v. IRS, et. al., S.D. Ohio, Case No. 1:13-cv-00341, Tea Party groups asserted that the IRS...more
The IRS has released Fiscal Year 2013 Enforcement statistics. In FY 2013, IRS Enforcement collected more revenue than FY 2012, with fewer employees and while examining fewer returns than in FY 2012. ...more
Treasury released its contingency plan to address the government shutdown. So, who will be home at the IRS? Here is what we know:
IRS will:
- continue automated collections activities
- continue processing tax...more
In Friedberg v. Comm’r, T.C. Memo 2011-238, the Tax Court granted summary judgment for the IRS, holding that an appraisal used to substantiate a facade easement donation amount was not a qualified appraisal because it...more
In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more
On March 15, 2013, the IRS issued a private letter ruling responding to a request for a determination of whether incentive awards paid to class representatives under a settlement agreement resolving a class action suit...more
When finalizing class action settlements, or paying damage awards after a class action judgment, it is important to be mindful of the taxation of these payments and the related IRS information reporting requirements triggered...more