Why Metadata Matters When Working with the IRS... [ read ]
Joel N. Crouch breaks down why metadata has become a critical factor in IRS examinations and tax litigation. Using the recent Lamstall Holdings Tax Court case as a backdrop, Mr. Crouch explains how metadata can influence penalty assertions, authenticate documents, and shape the evidentiary record.
Another Texas Contractor's Sales and Use Tax Conundrum: Is it "Maintenance" or Just Maintenance?... [ read ]
In the world of Texas sales and use tax, many concepts have proven to be challenging for contractors. Once such concept is the notion of "maintenance" given that it is generally excluded from work that may otherwise qualify as taxable repair and/or remodeling work. David Colmenero and Alex Pilawski discuss this concept of nontaxable "maintenance" and some of the issues it presents.
PFIC Rules & Late Form 8621: Understanding Your IRS Compliance Options... [ read ]
Matthew L. Roberts discusses the complexities of the PFIC tax rules and what happens when a taxpayer misses a Form 8621 filing or fails to make a timely PFIC election.
Beyond Reasonable Cause: Exploring Alternative IRS Penalty Defenses... [ read ]
Matthew L. Roberts explores alternative IRS penalty defenses beyond the familiar reasonable cause standard.
Claiming a Theft Loss? Be Careful, Tax Court Decision Shows... [ read ]
Matthew L. Roberts examines the IRS's guidance on theft loss deductions in light of a recent Tax Court decision. Mr. Roberts discusses key lessons from Potts v. Commissioner and some potential steps taxpayers can take to prove their theft loss deductions.
The Underrated Power of Tax Court Rule 124 in Tax Exempt Status Revocation Cases... [ read ]
Jeffrey M. Glassman discusses insights from a panel on Challenging Revocations to Tax-Exempt Status, including a practical suggestion from a Tax Court judge that could help organizations resolve these cases more efficiently.
IRS Unexpectedly Releases Guidance on ERC Limitations Under OBBA... [ read ]
Anthony P. Daddino dives into the IRS's newly released Fact Sheet 2025-07, which provides FAQs on the Employee Retention Credit (ERC) limitations enacted under the One Big Beautiful Bill (OBBA).
The Good, the Bad, and the Ugly: The Impact of the Goverment Shutdown on Taxpayers and the IRS... [ read ]
Firm partner Joel N. Crouch explores "The Good, the Bad, and the Ugly" of the ongoing federal government shutdown and its impact on both taxpayers and the IRS.
Government Shutdown Could Require More ERC Lawsuits - And Form 907 May Offer No Relief... [ read ]
Jeffrey M. Glassman examines how the ongoing federal government shutdown is disrupting IRS operations and what it means for employers with pending ERC refund claims.
IRS Faces Jarkesy Fallout: Tax Penalties Under Constitutional Scrutiny... [ read ]
Matthew L. Roberts breaks down how taxpayers are invoking the Supreme Court's Jarkesy decision to challenge IRS- imposed penalties on Seventh Amendment grounds.
