Resources Archive
April 4, 2023
Tax Decisions and Other Developments in the First Quarter of 2023... [ read ]
April 3, 2023
Josh Ungerman and Damon Rowe Publish an Article in the Dallas Bar Association Headnotes... [ read ]
Aprl 3, 2023
1014 Basis Adjustments and Irrevocable Grantor Trusts...
[ read ]
On April 17, 2023, the IRS released Revenue Ruling 2023-02, concluding that the basis adjustment incident to a person's death, under Section 1014 of the Code, generally does not apply to the assets of a grantor trust unless the assets are included in the grantor's gross taxable estate.
March 30, 2023
SWAN-Supporting Women Attorneys Network... [ read ]
March 24, 2023
Congratulations to Cari LaSala and Jana Simons for bein g named 2023 Texas Rising Stars... [ read ]
March 23, 2023
Council of Petroleum Accountants Societies (COPAS) Meeting... [ read ]
March 21, 2023
ERC Gets "Listed" - IRS Adds Employee Retention Credits to Dirty Dozen List...
[ read ]
Each year, the IRS identifies a dozen transactions -- inclusive of scams, structured transactions, and other transactions that the IRS just doesn't like – and puts them on its so-called "Dirty Dozen" list. Much like the Razzies, it's a not a list you want to make. And this year the IRS has added for the first time Employee Retention Credits ("ERC").
March 14, 2023
Part Three: Are Tax Returns Given to an IRS Agent Considered Filed?...
[ read ]
Last June, I wrote a blog post on a 9th circuit panel opinion in Seaview Trading LLC v. Commissioner, where the panel, in a 2-1 decision, reversed the Tax Court on the meaning of a "filed" return. The panel held that a tax return sent to an IRS agent was considered filed and started the three-year time period of limitations for the IRS to issue a notice of deficiency. This was important because the IRS did not issue a Notice of Deficiency until more than three years after the tax return was provided to the IRS examiner, and therefore was beyond the statute of limitations.
March 14, 2023
Managing Partner, Anthony Daddino was quoted in a March 13, 2023 Tax Note article written by Kristen A. Parillo... [ read ]
March 8, 2023
ERC: Is the IRS Trying to Ski Uphill?...
[ read ]
One of my favorite things to do is snow ski. I've been doing it for a long time and try to go on a couple of ski trips every year. In fact, I just returned from a trip with a couple of friends including my colleague Alan Davis, who is not only a great estate planning attorney, he is also an excellent skier. But I digress. Uphill skiing was brought to mind when I saw on March 7th the IRS released its third warning in six months regarding fraud and abuse in the Employee Retention Credit (ERC) program.
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