The recent Tax Court decision in Farhy demonstrates that clever and novel arguments can carry the day in complex tax litigation matters. In that case, the taxpayer stipulated that he: (1) had Form 5471 filing obligations...more
4/13/2023
/ Failure-to-File ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Lack of Authority ,
Settlement Agreements ,
Tax Abatement ,
Tax Court ,
Tax Liability ,
Tax Penalties ,
Tax Returns
Good tax attorneys will do whatever it ethically takes to win on behalf of their clients. Often, this means the attorney must not only have a good understanding of the substantive provisions at play, but also relevant...more
In most cases, IRS exam initiates FBAR assessments. And, after an IRS examiner determines that an FBAR penalty is appropriate, taxpayers are generally afforded pre- or post-assessment appeals rights with the IRS Independent...more
Ordinarily, taxpayers file their income tax returns each year with the IRS and hear nothing more. Rather, the Internal Revenue Service (“IRS”) simply processes the tax return, assesses the reported amount of tax due, and...more
This program is the first of Freeman Law’s multi-class course designed to prepare CPAs and Enrolled Agents for the Tax Court’s admissions examination. Participants will receive an overview of the Tax Court and will learn...more
8/19/2021
/ CPAs ,
Estate Tax ,
Federal Rules of Evidence ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Legal Ethics ,
Subject Matter Jurisdiction ,
Tax Court ,
Tax Litigation ,
Webinars
Join us as we discuss important developments and bring you up to speed on current initiatives. Many businesses are still facing unprecedented challenges, and we are here to provide insights.
During this information-filled...more
7/23/2021
/ Automatic Stay ,
Cryptocurrency ,
Enforcement ,
Income Taxes ,
IRS ,
Reasonable Compensation ,
State Taxes ,
Tax Benefits ,
Tax Court ,
Tax Litigation ,
Tax Planning ,
Webinars
The proper federal tax treatment for any given settlement payment is something of an enigma. Generally, federal courts (and thus, the IRS) respect the terms of a settlement agreement if the terms are clear and the parties...more
Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more
Tax professionals are intimately familiar with certain reporting requirements under the Internal Revenue Code. Indeed, a failure to properly and timely report a position on a return where it is otherwise required may result...more
The law has always favored the term “reasonable.” For example, the law affords protection against a negligence lawsuit if a person can demonstrate he or she acted as a reasonable person would have under similar...more
10/2/2020
/ Appeals ,
Business Expenses ,
C-Corporation ,
Corporate Taxes ,
Income Taxes ,
IRS ,
Reasonable Cause Defense ,
Reasonable Compensation ,
Tax Allowances ,
Tax Court ,
Tax Penalties