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 May 13, 2022, in Reserve Mechanical Corporation v. Commissioner,[1] the U.S. Court of Appeals for the Tenth Circuit affirmed a Tax Court decision that a micro-captive insurance
Continue Reading Another Micro-Captive-Case Loss: 10th Circuit Affirms Tax Court Ruling in Reserve Medical Corp. v. Commissioner
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
In February 2020, the IRS announced that it would step up efforts to contact high-income taxpayers (defined as earning $100,000 or more per year), who in prior years have failed
Continue Reading The IRS Announced a New Non-Filer Initiative Over a Year Ago – Now We See the Enforcement
Recent John Doe summonses show the IRS is expanding its use of those summonses to aggressively investigate potential tax evasion. Within the past week, the IRS has received authorization to
Continue Reading The IRS Continues Aggressive Use of John Doe Summonses to Investigate Tax Evasion Related to Use of Cryptocurrency, Offshore Service Providers
Taxpayers that have engaged in cryptocurrency transactions should be aware that the Internal Revenue Service is seeking customer records from cryptocurrency exchanges. The Department of Justice recently filed petitions in
Continue Reading IRS Actively Seeking Information Regarding Cryptocurrency Via John Doe Summonses
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 Coronavirus Disease 2019 (COVID-19) pandemic caused the closure of Internal Revenue Service offices and service centers nationwide and the plummeting of new tax examinations. Although certain functions and ongoing
Continue Reading IRS Audit and Investigation Priorities Now That the IRS Is Back in Business