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Internal Revenue Code (IRC) Department of Justice (DOJ) Tax Liability

Fox Rothschild LLP

DOJ Seeks Injunction Barring Promotion of Monetized Installment Sales

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An installment sale occurs when property is disposed of and at least one payment is received after the tax year of the disposition. See I.R.C. § 453. Under a standard installment sale, the buyer makes scheduled payments to...more

Holland & Hart LLP

the buzz: Cannabis News & Policy Update | February 2025 Special Tax Edition

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Welcome to the buzz: Special Tax Edition. April 15 is just over two months away. This Special Tax Edition includes practical considerations to help you prepare for tax filing season, including: A former DOJ attorney...more

Polsinelli

CPA gets 25 years for Promoting Conservation Easement Deductions

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Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

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Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

McDermott Will & Emery

Can the Government Sue for Tax Debts Outside IRC Procedures?

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On June 1, 2023, in United States v. Liberty Global, Inc.[1], the US District Court for the District of Colorado held that the US Department of Justice (DOJ) can assert and seek judgment for federal income tax deficiencies...more

Miller Canfield

High-Profile Case Highlights Government's Common Law Right to Pursue Tax Deficiencies in Court

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A federal district court ruled in a high-profile case that the Justice Department may rely on common law rather than the statutory notice of tax deficiency procedure in the Internal Revenue Code to assert a federal income tax...more

Oberheiden P.C.

What Tax Preparers Need to Know Before Sitting for an IRS CI Interview

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The Internal Revenue Service’s Criminal Investigation Division (IRS CI) is targeting tax preparers or the ones who prepare tax returns in 2022. IRS CI is focusing its efforts on tax preparers who underreport their clients’...more

Freeman Law

IRS Voluntary Disclosures and Criminal Employment Tax Violations

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Taxpayers who employ workers have obligations under federal law to withhold and remit federal employment taxes to the IRS. In addition to this withholding and payment requirement, federal law also imposes certain reporting...more

Freeman Law

DOJ-Tax Alleges President of We Build the Wall Filed a False Tax Return and Committed Wire Fraud

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Taxpayers who file false tax returns with the IRS can find themselves in hot water.  Indeed, section 7206(1) of the Internal Revenue Code (“Title 26”) makes it a felony to file a false return when the taxpayer knows that the...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

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A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

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