In Polselli v. IRS, the Supreme Court was tasked with determining whether the IRS, pursuant to powers granted in Internal Revenue Code (IRC) section 7609(c)(2)(D)(i), is entitled to issue third-party summonses, without notice, for bank account records in which the taxpayer targeted by the summons does not have a legal interest.
Continue Reading Supreme Court Affirms IRS Power to Summons Bank Information Without Notice to Delinquent Taxpayer
IRS Notice 2023-11 provides temporary relief for foreign financial institutions to provide U.S. taxpayer identification numbers for preexisting accounts.
Continue Reading IRS Temporary Relief for Foreign Financial Institutions Required to Report U.S. Taxpayer Identification Numbers Under FATCA: Potential Implications for ‘Accidental Americans’
The proposed regulations demonstrate that the IRS is taking a proactive approach in addressing the APA challenges to its method for identifying listed transactions. The IRS makes clear that it will continue to aggressively pursue syndicated conservation easement transactions.
Continue Reading Responding to Recent Taxpayer Victories, IRS Issues Proposed Regulations Identifying Syndicated Conservation Easement Transactions as Listed Transactions
In Green Valley Investors, LLC, Et Al., Bobby A. Branch, Tax Matters Partner, v. Commissioner, the Tax Court on Nov. 9 abated Internal Revenue Code (I.R.C.) § 6662A penalties
Continue Reading U.S. Tax Court Invalidates Conservation Easement Notice, Abates Reportable Transaction Penalty for Failure to Comply with Administrative Procedure Act
On Oct. 3, 2022, the U.S. Supreme Court granted certiorari in In Re Grand Jury. On appeal from the Ninth Circuit, In Re Grand Jury considers whether the attorney-client
Continue Reading U.S. Supreme Court Grants Certiorari in Case Involving Application of Attorney-Client Privilege to Dual-Purpose Communications with Tax Attorneys
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
Equine industry assets that could be subject to government seizure include real estate, equipment, and the horses themselves, although horses valued below $10,090 are exempt from levy.
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Continue Reading Your Horse May Be Subject to IRS Seizure
In a major change in New York’s law on statutory residency, in a June 30 ruling in Obus v. New York State Tax Appeals Tribunal, the New York State
Continue Reading Greenberg Traurig Secures Win for Client in Obus v. New York State Tax Appeals Tribunal; Ruling is Major Change in New York Law on Statutory Residency
In a rare change of position, on June 2, 2022, the district court granted the government’s motion in CIC Services, holding the IRS was not required to return the
Continue Reading District Court Grants Government’s Motion for Reconsideration in CIC Services: IRS Not Required to Return Disclosure Documents Obtained Under Notice 2016-66
In Boechler, P.C. v. Commissioner, the Supreme Court held the 30-day time limit to file a Tax Court petition for review of a collection due process determination is not
Continue Reading Supreme Court Rules Against IRS on US Tax Court Jurisdictional Issue