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Internal Revenue Code (IRC) Tax Liability Statute of Limitations

Ballard Spahr LLP

Finally Received the Employee Retention Credit? Now What? A Guide to ERC Income Tax Consequences

Ballard Spahr LLP on

It appears that the flood gates have opened and that the IRS is finally processing and paying claims for the employee retention credit (ERC) en masse. After waiting a very long time (often years) with no contact from the IRS,...more

Freeman Law

Tax Court in Brief | Fairbank v. Comm’r | Reporting Obligations for Foreign Trust Income and Ownership; Statute of Limitations

Freeman Law on

Summary:  At its core, this 31-page opinion regards married U.S. citizen taxpayers, Leigh Fairbank (Leigh) and Barbara Fairbank (Barbara), challenge to deficiency notices issued for the tax years in issue (2003 through 2009...more

Miller Nash LLP

Today in Tax: Spin-offs, Tax Elections, and Subpart F

Miller Nash LLP on

Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on existing law cannot be revoked if later regulatory changes...more

Gray Reed

Statute of Limitations in Tax Cases – The Basics

Gray Reed on

What is the Statute of Limitations? - The Internal Revenue Code limits the time in which the government may assess tax. There are two civil statutes of limitations.  The first is the period during which the IRS can assess...more

Freeman Law

Missed Window—Taxpayer Loses Chance to Sue IRS on Claim for Refund

Freeman Law on

In The Merry Wives of Windsor, William Shakespeare penned the famous line: “Better three hours too soon than a minute too late.” And such sentiments of time are certainly true in the tax world. One minute late may have...more

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

BCLP

Employer Shared Responsibility Payments May Have No Statute of Limitations

BCLP on

In Chief Counsel Memorandum 20200801F, released on February 21, 2020, the IRS established its position that no statute of limitations applies to employer shared responsibility payments that may be assessed under Section 4980H...more

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