News & Analysis as of

Internal Revenue Code (IRC) Enforcement Actions Tax Liability

Rivkin Radler LLP

Observations on Charities, Taxes, and Cash Flow

Rivkin Radler LLP on

Few provisions of the Code have a single, clear meaning that leaves no room for interpretation. Even many of those that, on the surface, appear fairly straightforward, are usually open to alternative “understandings.”...more

Farrell Fritz, P.C.

Relocating? Be Sure to Add the IRS to Your Change of Address Checklist

Farrell Fritz, P.C. on

In a recent decision, the U.S. District Court for the Central District of California held that the Internal Revenue Service (“IRS”) did not violate Internal Revenue Code (“IRC”) Section 7433 or related regulations when it...more

McDermott Will & Emery

IRS Roundup January 20 – 31, 2025

McDermott Will & Emery on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the weeks of January 20, 2025 – January 24, 2025, and January 27, 2025 – January 31, 2025....more

Rivkin Radler LLP

Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?

Rivkin Radler LLP on

Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Farrell Fritz, P.C.

Federal Tax Controversies and the Appeals Resolution Process

Farrell Fritz, P.C. on

The Taxpayer First Act (“TFA”), which was signed into law on July 1, 2019, makes the most significant changes to administrative procedures since the Internal Revenue Service Restructuring and Reform Act of 1998. In addition...more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

Rivkin Radler LLP on

If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

Freeman Law on

In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Gray Reed

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

Gray Reed on

We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

Polsinelli

CPA gets 25 years for Promoting Conservation Easement Deductions

Polsinelli on

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

Gray Reed on

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

Freeman Law

Section 6751(b) Penalty Approval Circuit Split

Freeman Law on

Eleventh Circuit Sides with Ninth Circuit on Section 6751(b) Circuit Split - Introduction: Section 6751(b) and the Timing of Supervisory Approval of a Penalty - The Eleventh Circuit’s decision in Kroner v. Commissioner,...more

Gray Reed

IRS Penalty Denied Because of Poor Penmanship

Gray Reed on

Many people, myself included, can sometimes be accused of poor penmanship. As our paperwork becomes more and more electronic, we write less and less down with pen and paper. However, a recent decision from the tax court may...more

Gray Reed

Non-Willful FBAR Penalties Will be Much Higher in the Fifth Circuit

Gray Reed on

On November 30, 2021, the Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful penalties are capped at $10,000 per FBAR filing instead of the $10,000 per unreported bank account...more

Holland & Knight LLP

Senate Finance Committee Begins Review of Nonprofit Hospitals

Holland & Knight LLP on

• Based on a new review of nonprofit hospitals by Senate Finance Committee Chairman Charles Grassley (R-Iowa), a congressional investigation is expected that directly requests a number of specific hospitals to answer...more

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