Photo of Scott E. Fink

Scott E. Fink focuses on civil and criminal federal and state tax controversies and litigation. He represents corporations, partnerships, estates and individuals before the Internal Revenue Service, and state and local tax authorities in examinations, collection problems, administrative appeals, and in court.

In July 2019 the IRS identified post offshore voluntary disclosure program (OVDP) compliance as a campaign. The purpose of the campaign is to pursue those OVDP participants who fail to
Continue Reading Your Offshore Voluntary Disclosure May Be Long Over but the IRS May Be Looking at Your Ongoing Tax Compliance

The IRS Office of Chief Counsel announced in Issue Number IR-2020-130 that it will be making a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving


Continue Reading IRS Offers Settlement to Syndicated Conservation Easement Investors with Cases Pending in U.S. Tax Court

On March 20, 2020, the IRS issued Notice 2020-18, extending the April 15, 2020, due date for filing federal income tax returns and making federal income tax payments to
Continue Reading IRS Extends Income Tax Filing Deadline to July 15, 2020, and Removes Cap on Tax Payments Deferred to July 15, 2020

On Nov. 29, 2018, the IRS released a memorandum with new procedures for all voluntary disclosures following the end of the Offshore Voluntary Disclosure Program (OVDP) on Sept. 28, 2018.
Continue Reading IRS Releases New Voluntary Disclosure Procedures for Post 9-28-2018 Offshore and Domestic Disclosures

The IRS announced that it will end the Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018.  The IRS is pressing taxpayers with undisclosed foreign accounts, entities and income to
Continue Reading IRS Announces it Will End the Offshore Voluntary Disclosure Program Effective September 28, 2018