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Tax Fraud Internal Revenue Code (IRC) Tax Planning

McDermott Will & Emery

Weekly IRS Roundup November 18 – November 22, 2024

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Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18, 2024 – November 22, 2024. ...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What...

Foster Garvey PC on

Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

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Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Lowndes

Too Good To Last? IRS Halts Processing of ERC Claims

Lowndes on

While not as well-known as the Paycheck Protection Program, the Employee Retention Credit (“ERC”) program was another form of Covid relief provided by the federal government to businesses in 2020 and 2021. The ERC program...more

Gray Reed

IRS Imposes Immediate Moratorium on Employee Retention Credit (ERC) Claims

Gray Reed on

For some time, the IRS has cautioned taxpayers about filing false or fraudulent ERC claims.  More recently, on September 14, 2023, the IRS issued a News Release, IR-2023-169, indicating that it would no longer process ERC...more

Freeman Law

IRS Criminal Investigation’s Top Ten Cases of 2021

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Many (if not most) people and organizations approach a new year by setting new goals or implementing changes. This exercise, however, requires a reflection on the previous year’s events, successes, and failures. And...more

Freeman Law

Fraud Penalty Affirmed: In Not-So-Chic Fashion, the Ninth Circuit Upholds Fraud Penalties in Chico

Freeman Law on

In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

Freeman Law

How to Successfully Request IRS Penalty Relief

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Federal tax penalties have always been an IRS priority.  But, perhaps more so today than three decades ago.  For example, in 1987, the IRS reported that it had assessed penalties of approximately $14 billion.  Compare that...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

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