Lee Meyercord

Lee Meyercord

Thompson & Knight LLP

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GAO Issues Final Report with Recommendations to Improve Large Partnership Audits

The Government Accountability Office (“GAO”) recently issued its final report with recommendations to improve the efficiency and effectiveness of large partnership audits, a copy of which is available here. The GAO issued...more

10/8/2014 - Audits Final Guidance GAO IRS Partnerships TEFRA

Disregarded Entity May Select Different Accounting Method than its Owner

In a recent Chief Counsel Advice (“CCA”), the IRS determined that a disregarded entity for federal income tax purposes (the “LLC”) operated a separate and distinct trade or business from that of its owner (the “Company”) and...more

10/3/2014 - Corporate Taxes Disregarded Entities Financial Accounting IRS Limited Liability Companies Manufacturers

GAO Issues Preliminary Report on Challenges in Auditing Large Partnerships

The Government Accountability Office (“GAO”) recently issued a preliminary report on the challenges in auditing large partnership returns, a copy of which is available here. The GAO issued an interim report earlier this year...more

9/26/2014 - Audits GAO IRS Partnerships

Mary Mcnulty Quoted On Court Of Federal Claims Decision In Interest Netting Case

Mary McNulty was quoted in a Tax Notes Today article (subscription required) on the Court of Federal Claims decision in Wells Fargo. In Wells Fargo, the Court of Federal Claims found that a taxpayer may net underpayment...more

7/22/2014 - Acquisitions Overpayment Wells Fargo

Supreme Court Provides Standard for Evidentiary Hearing in IRS Summons Enforcement Proceeding

On June 19, 2014, the Supreme Court unanimously ruled that taxpayers have a right to an evidentiary hearing in an IRS summons enforcement action when the taxpayer “offers some credible evidence supporting his charge” of...more

7/3/2014 - Bad Faith Corporate Taxes Document Requests Enforcement Enforcement Actions IRS Partnerships Request For Information SCOTUS Summons US v Clarke

Court of Federal Claims: Merged Corporations are the Same Taxpayer for Interest Netting

In Wells Fargo, the Court of Federal Claims held that a taxpayer may net underpayment balances and overpayment balances among merged entities under Section 6621(d). Section 6621(d) provides that, to the extent the “same...more

7/3/2014 - Banks Corporate Taxes Mergers Tax Liability Wells Fargo

Supreme Court hears Oral Arguments in Summons Enforcement Case

The IRS may summon any person to produce books, papers, records or any data that may be relevant in an exam. If a summoned party refuses to comply, the IRS must petition a district court to enforce the summons. The summoned...more

5/29/2014 - Enforcement Actions Evidentiary Hearings Information Document Requests IRS Summons

Tax Court finds Roth IRAs were Pass-thru Partners

The complex TEFRA procedures for partnership audits and litigation require the IRS to notify partners of the beginning of a partnership audit. The IRS is not required to give notice to indirect partners, who own their...more

5/19/2014 - IRS Pass-Through Entities Super Roth IRA TEFRA

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