The potential tax consequences to a debtor and tax reporting obligations of a creditor can become a contentious issue when settling disputed debts, although the issue often arises as an afterthought once the primary...more
The IRS’s reach in collecting unpaid and assessed taxes is broad, pervasive, and aimed “to reach every interest in property that a taxpayer may have” United States v. National Bank of Commerce, 472 U.S. 713, 719–720 (1985)...more
Given the recent expiration of the IRS’s People First Initiative on July 15, the return of IRS employees to offices and service centers, and this news release reminding taxpayers that collection activities would start...more
Every year the IRS compiles a “Dirty Dozen” list of scams and abusive schemes that may impact taxpayers. On July 16, 2020, the IRS released it 2020 Dirty Dozen List, which almost exclusively focuses on the schemes and tactics...more
At various points in time, the IRS offers “initiatives” to assist businesses and individuals with various tax issues. Most often these initiatives offer favorable terms or inducements to a class of taxpayers with respect to...more
Less than 48 hours after we gave a hat-tip to the agility displayed by the IRS since the onset of the COVID-19 pandemic and its ability to create new procedures and policies in real time, the IRS had already released at least...more
Despite significant prior resource constraints (people and technology), the IRS continues to be remarkably agile and quick to issue pertinent guidance and notifications of policy changes during this global COVID-19 pandemic....more
The new centralized audit regime for partnerships established by the Bipartisan Budget Act of 2015 (“BBA”) has been in effect since January 1, 2018, but is your partnership or LLC treated as a partnership for tax purposes...more