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Tax Audits Tax Liability Tax Assessment

Rivkin Radler LLP

Applying the Federal Priority Statute to The Attorney as Client’s “Corporate Executive”

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Over their career, every tax practitioner has had many client-taxpayers against whom a government’s taxing authority – be it federal, state, or local – has asserted and then assessed a tax deficiency. There are many...more

FBT Gibbons LLP

Avoiding IRS Accuracy Penalties for a Substantial Underpayment of Tax

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There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more

Vinson & Elkins LLP

Whose Fraud Is It Anyway? The Expanding Reach of the Fraud Exception to the Statute of Limitations on Tax Assessment

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Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more

Rivkin Radler LLP

Visiting the Sins of the Tax Preparer Upon the Taxpayer? The Fraud Exception to the Limitations Period on Assessment

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As we discussed a few weeks ago, the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection function, the agency may...more

Buckingham, Doolittle & Burroughs, LLC

Earth-shattering tax liability means doomsday for vendors: Don’t put your personal net worth at-risk

Vendors selling out of state but not collecting sales tax are on a path to suffering severe financial loss. The tax liability could be astronomical – enough to devastate a business – as high as 10% or more of total sales for...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

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There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

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