Articles Archive
March 23, 2022
Mann Construction Plaintiffs Take IRS Back to Court...
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Mary Wood was quoted in the March 23, 2022 Tax Analysts article, "Mann Construction Plaintiffs Take IRS Back to Court." A Michigan couple who successfully challenged a listed transaction notice claims in a new lawsuit that the IRS is refusing to issue penalty refunds for later tax years, despite the Sixth Circuit's holding that the notice is invalid.
March 22, 2022
Court Vacates IRS Microcaptive Notice...
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Mary Wood was quoted in the March 22, 2022 Tax Analysts article, "Court Vacates IRS Microcaptive Notice," by Kristen A. Parillo. In Tennessee, a district court has invalidated and vacated the IRS's microcaptive notice, rejecting the Justice Department's suggestion that it send the notice back to the agency to fix its procedural deficiencies.
February 16, 2022
IRS Updates Voluntary Disclosure Form with Electronic Bent...
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Josh O. Ungerman was quoted multiple times in the Feb. 15, 2022 article, "IRS Updates Voluntary Disclsoure Form with Electronic Bent," in Tax Analysts 2022 by Nathan J. Richman. The article addresses the IRS's newest version of the two-part letter for taxpayers looking to voluntarily disclose past noncompliance.
February 2, 2022
Be Patient on Reportable Transaction Penalties, Attorneys Say...
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Mary Wood was quoted in the Tax Analysts article published on Feb, 2, 2022, Doc. 2022-3533, "Be Patient on Reportable Transaction Penalties, Attorneys Say," by Kristen A. Parillo.
Ms. Wood was a panelist at the recent American Bar Association Section of Taxation virtual meeting discussing the legal uncertainty regarding IRS penalty assessments amid pending court cases in which taxpayers have challenged the validity of IRS notices, issued without a formal comment period, that designate listed or reportable transactions requiring disclosure by taxpayers and material advisers.
September 29, 2020
HILL TAX BRIEFING: Taxes in Focus Heading Into First 2020 Debate...
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Josh Ungerman was quoted in the Bloomberg article, "HILL TAX BRIEFING: Taxes in Focus Heading Into First 2020 Debate," by Colin Wilhelm, Kaustuv Basu and Patrick Ambrosio on September 29, 2020. Reproduced with permission. Published September 29, 2020. Copyright 2020 by BGOV LLC (877-498-3587)
September 16, 2020
Taxpayers' FBAR Fifth Amendment Gambit Fails...
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Josh Ungerman was quoted in the TaxNotes article, "Taxpayers' FBAR Fifth Amendment Gambit Fails," by Andrew Velarde on September 16, 2020.
July 10, 2020
New IRS Practice Unit Explains Penalty Relief...
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Mike Villa was quoted in the TaxNotes article, "New IRS Practice Unit Explains Penalty Relief," by Kristen A. Parillo on July 10, 2020.
February 10, 2020
The Section 199A Final Regulations – Important Clarifications, Part 2...
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Steve Beck has published the article, "The Section 199A Final Regulations – Important Clarifications, Part 2," in Today's CPA Magazine, January/February 2020 issue.
January 2, 2020
Appraiser Accuses IRS, DOJ of Violating Taxpayer Privacy Rules...
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Josh Ungerman was quoted in the article, "Appraiser Accuses IRS, DOJ of Violating Taxpayer Privacy Rules."
November 26, 2019
