News & Analysis as of

Tax Appeals Internal Revenue Service

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

Rivkin Radler LLP on

You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Vinson & Elkins LLP

IRS’s Alternative Dispute Resolution Has Room for Improvement

Vinson & Elkins LLP on

The IRS Independent Office of Appeals has renewed its focus on alternative dispute resolution (ADR). In this article, V&E counsel Stephen Josey examines the ADR program and dives into how the agency can tweak its mediation...more

McDermott Will & Emery

Supreme Court Overrules Chevron, Opening Door for New Tax Reg Challenges

McDermott Will & Emery on

On June 28, 2024, the Supreme Court of the United States reshaped the federal tax landscape when it overturned the long-standing Chevron doctrine in Loper Bright Enterprises v. Raimondo, No. 22-451. The Chevron doctrine, a...more

Holland & Knight LLP

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

Holland & Knight LLP on

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Buckingham, Doolittle & Burroughs, LLC

What to Do If Your Business Receives a Tax Audit

When your business receives an audit engagement letter, don’t panic. While an audit may be time-consuming, costly, and invasive, having an experienced advocate on your side to navigate you through the process and represent...more

Rivkin Radler LLP

IRS Cannot Offset Taxpayer’s Refund With A Disputed Tax Liability

Rivkin Radler LLP on

Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more

Cadwalader, Wickersham & Taft LLP

Liberty Global to Appeal Its Foreign Tax Credit Tax Court Loss

Liberty Global has announced that it will challenge the November 2023 Tax Court finding that the company had incorrectly boosted its foreign tax credits by failing to account for gains that exceeded the total foreign loss on...more

McDermott Will & Emery

IRS Appeals Is Looking for Suggestions on Improving Conference Access

McDermott Will & Emery on

The Internal Revenue Service (IRS) has invited suggestions on improving conference options at the Independent Office of Appeals (IRS Appeals) for taxpayers and representatives who are not located near an IRS Appeals office...more

Rivkin Radler LLP

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

Rivkin Radler LLP on

Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more

Freeman Law

Tax Court in Brief | Lipka v. Comm’r | Collection Alternatives, Economic Hardship, and Abuse of Discretion

Freeman Law on

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Fox Rothschild LLP

AICPA Urges IRS to Extend Deadline for COVID-19 Penalty Relief, Expand Scope

Fox Rothschild LLP on

The American Institute of CPAs (AICPA) has applauded the Internal Revenue Service for granting automatic penalty relief related to select 2019 and 2020 returns, but asked for two tweaks to the process: The group wants...more

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

Rivkin Radler LLP on

Where is the Economy Heading? According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more

Rivkin Radler LLP

Statutory Residence in New York: Time to Rethink the “Permanent Place of Abode” Test?

Rivkin Radler LLP on

Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more

Miller Canfield

Procedural Actions Following the Supreme Court Remand in Boechler

Miller Canfield on

Key Takeaways: ..In Boechler P.C., v. Commissioner (“Boechler”), the Supreme Court held that the thirty-day period to petition the Tax Court for review of an adverse determination by the IRS Appeals Office in a collection...more

Rivkin Radler LLP

Will New York Be Looking At Your Federal Tax Return? Probably

Rivkin Radler LLP on

State Finances- Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more

McDermott Will & Emery

Weekly IRS Roundup December 6 – December 10, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 6, 2021 – December 10, 2021... December 6, 2021: The IRS published updated guidance on...more

McDermott Will & Emery

IRS Provides Guidance to LB&I Examiners on Requesting Participation in Appeals Conferences

McDermott Will & Emery on

We recently covered the Appeals Team Case Leader Conferencing Initiative: Summary of Findings and Next Steps (Appeals Summary) in relation to the participation of Large Business & International (LB&I) exam teams and Internal...more

McDermott Will & Emery

Show Me the Money: IRS Introduces Webpage for Large Refunds Subject to JCT Review

McDermott Will & Emery on

When we previously wrote about the Joint Committee on Taxation’s (JCT) process for reviewing refund claims granted by the Internal Revenue Service (IRS), we explained that the IRS generally must submit proposed refunds in...more

Gray Reed

A Guide to Office Audits with the IRS

Gray Reed on

When a tax return has been selected for office examination, generally the examination of the return will be conducted at the office of the IRS.  Normally a taxpayer will find an office examination has begun when he or she has...more

Gray Reed

The Basics of the IRS and Tax Audits

Gray Reed on

There is a general misconception about what the IRS can and cannot do.  Owing money to the IRS is not like owing any other creditor.  The IRS is one of only a few creditors who can seize and sell your home even though state...more

Gray Reed

Going to Appeals – Preparing the Protest

Gray Reed on

Overview of the Appeals Process - The goal of the Appeals Office is to settle as many cases as possible within the broad guidelines of its Mission Statement...more

Gray Reed

Tips for Working with IRS Revenue Agents During an Audit – Part 2

Gray Reed on

If you haven’t read Part 1 of this blogpost, you might appreciate the background in that post.  That post dealt primarily with the concepts of communication during the audit....more

McDermott Will & Emery

IRS Appeals Large Case Pilot Program Ends

More than three years ago, the Internal Revenue Service (IRS) revised the Internal Revenue Manual to provide IRS Appeals Division (Appeals) with discretion to invite representatives from the IRS Examination Division (Exam)...more

Farrell Fritz, P.C.

Tax Challenges & Disputes Update

Farrell Fritz, P.C. on

As the COVID-19 pandemic continues to impact our lives, federal and state taxing authorities understand the challenges individuals and businesses are facing, and have issued guidance and a variety of updates....more

Rosenberg Martin Greenberg LLP

Internal Revenue Service Announces “People First Initiative” In Wake of COVID-19

Initiative Temporarily Suspends Many Payment Requirements and Enforcement Actions Earlier this week, the Internal Revenue Service (“the Service”) unveiled its new People First Initiative (“the Initiative”), an effort by...more

47 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide