IRS Notches Another Victory in Safdieh on IRS Form 5471 Penalty... [ read ]
Matthew L. Roberts examines the evolving judicial landscape surrounding IRS Form 5471 penalties in light of the Second Circuit's recent decision in Safdieh v. Comm'r.
The Fifteenth Court of Appeals Holds that Returnable Containers May Qualify for the Manufacturing Exemption Creating Potential Opportunities for Refund Claims... [ read ]
David E. Colmenero and Alex J. Pilawski examine the Fifteenth Court of Appeals' recent decision in Hancock v. ChampionX, LLC, which holds that returnable containers may qualify for Texas's Manufacturing Exemption.
Navigating the Federal Tax Consequences on Settlements and Judgments... [ read ]
Matthew L. Roberts explores the federal income tax consequences associated with litigation settlements and judgments, focusing on how the origin of the claim doctrine determines whether settlement payments are taxable or non-taxable.
FBAR Willfulness Easier to Prove Under Recent Reyes Second Circuit Decision... [ read ]
Matthew L. Roberts examines the Second Circuit's recent decision in U.S. v. Reyes and its significance to IRS compliance options.
Fifth Circuit Rejects IRS "Passive Investor" Test for Limited Partners in Self-Employment Tax Case... [ read ]
Naveid P. Jahansouz examines the Fifth Circuit's rejection of the IRS's effort to restrict the limited partner exception to passive investors.
Memo to IRS-CI: Don't Forget to Tout Your Legal-Source Income Casework!... [ read ]
Joseph A. Rillotta takes a closer look at IRS Criminal Investigation's recently released "Top 10 Cases of 2025" and highlights the absence of any legal-source income tax evasion cases.
Just In Time for the Holidays, IRS Criminal Investigation Releases Its 2025 Top 10 Cases... [ read ]
Joel N. Crouch breaks down the IRS Criminal Investigation Division's newly released Top 10 cases of 2025, just in time for the holidays.
Recent FTC Complaint Shows Taxpayers were Victims of IRS Collection Scheme... [ read ]
Matthew L. Roberts explores a recent development with serious implications for taxpayers facing IRS collection activity: how scammers are exploiting public Notices of Federal Tax Lien.
The Grinch's Tax Issues: Why Even a Mountaintop Hermit Can't Escape the IRS... [ read ]
Joel N. Crouch takes a lighthearted look at what would happen if the Grinch ever found himself on the IRS's radar.
Changes to IRS Voluntary Disclosure Program are Coming... [ read ]
Jeffrey M. Glassman shares insights from the American Bar Association's 2025 Criminal Tax Fraud and Tax Controversy Conference, where IRS Criminal Investigation Chief Guy Ficco announced that changes to the IRS voluntary disclosure program are coming.
