Resources Archive
June 5, 2023
Sometimes "The Truth" is Reasonable Cause for IRS Penalties...
[ read ]
I was reminded of a Seinfeld episode when I read the summary opinion by the Tax Court in Tracy v. Commissioner, T.C. Summ. Op. 2023-30, where the judge held that the taxpayer had reasonable cause for his failure to file employment tax returns and pay employment taxes because he had a good story to tell.
June 1, 2023
Josh Ungerman was quoted in a Tax Notes article published today written by Lauren Loricchio, titled "IRS Could Do More to Resolve Disputes via Mediation, GAO Says."... [ read ]
May 30, 2023
Mary Wood was quoted in the recent Tax Notes article, "Training Docs Suggest IRS Is Focused Only on Most Serious ERC Fraud"written by Lauren Loricchio.... [ read ]
May 24, 2023
2023 Texas Bank and Trust - Longview, TX... [ read ]
May 24, 2023
Sometimes the IRS is Even Steven...
[ read ]
Seinfeld fans will recall the episode called "Even Steven", where Jerry was Even Steven. If he lost a gig, another one became available. If he lost money, he would find the same amount somewhere else.
In two recent cases, the IRS was Even Steven, like Jerry. In one case, Lakepoint Land II LLC v. Commissioner, Tax Court Docket No. 13925-17, the IRS stands accused of knowingly using a backdated document to win a penalty defense. In the second case, Soleimani v. Commissioner, T.C. Memo 2023-60, the IRS prevailed in disallowing millions of dollars in deductions, after the court determined the taxpayers were relying on forged documents and information from a fictious lawyer.
May 18, 2023
50th Annual North American Petroleum Accounting Conference... [ read ]
May 17, 2023
2023 Texas Bank and Trust, Tyler, TX... [ read ]
May 10, 2023
Financial Planning Association DFW Chapter Meeting... [ read ]
May 6, 2023
2023 ABA Section of Taxation May Tax Meetings... [ read ]
May 5, 2023
ABA Section of Taxation 2023 May Tax Meetings... [ read ]
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