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.

On Aug. 29, the IRS released a new section to the Internal Revenue Manual (IRM), 20.1.1.3.3.2.2, providing penalty relief for certain taxpayers filing 2019 and 2020 returns in response to
Continue Reading IRS Revisions to Internal Revenue Manual Clarify Who Is Eligible for Late Filing Penalty Relief

The Fourth Circuit in Cook v. United States held that federal tax penalty assessments and the payments the debtor made were not voidable fraudulent transfers that generally allow debtors to
Continue Reading 4th Circuit Holds Tax Penalty Obligations Are Not Voidable Fraudulent Transfers

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