Bar Exam Toolbox Podcast Episode 134: Listen and Learn -- Authority of Agents
They Are People, Not Aliens- Believe it or not, IRS Agents are normal people just like you. They brush their teeth, pack their kids’ lunches, and drink coffee before going to work each day. Or as some would say, they, too,...more
Field examinations involve returns with more complex issues, thereby requiring examination by someone more knowledgeable in the field of accounting and the Internal Revenue laws. Field examinations are conducted by Revenue...more
In CCA 201501013, the IRS found that an offshore fund making loans to U.S. borrowers was engaged in a U.S. trade or business where multiple loans owned by the fund were originated by an agent of the fund. This conclusion is...more