FBAR Penalty Struck Down on Seventh Amendment Concerns... [ read ]
Matthew L. Roberts examines a recent Northern District of Texas decision striking down IRS-imposed FBAR penalties on Seventh Amendment grounds. Building on the Supreme Court's 2024 Jarkesy ruling, the court in U.S. v. Sagoo concluded that the Government's FBAR collection process, where the IRS acted as "prosecutor, jury, and judge," violated taxpayers' constitutional right to a jury trial
Three OBBBA Provisions You Should Know for 2025... [ read ]
Matthew L. Roberts dives into three major tax provisions in the recently enacted One Big Beautiful Bill Act (OBBBA) that businesses need to know for 2025.
The Newly Formed 15th Court of Appeals Issues First Tax-Related Decision Involving the Texas Comptroller Holding that a Tax Lien Did Not Apply to Taxpayers' Homestead... [ read ]
The recently formed 15th Court of Appeals in Texas recently issued its first tax-related decision involving the Texas Comptroller. David E. Colmenero and Alex J. Pilawski discuss the court's holding which determined that a notice of tax lien filed by the Texas Comptroller did not attach to the taxpayers' homestead.
Tax Issues Every NIL Athlete Should Know... [ read ]
Joel N. Crouch breaks down the tax challenges student-athletes face as they enter the world of Name, Image, and Likeness (NIL) deals. From self-employment taxes and estimated payments to multi-state filing obligations and the treatment of free gear or perks, he highlights the key issues every NIL athlete needs to understand.
Contractors: Are You a Victim of the Infamous Texas Sales and Use Tax "5% Test"?... [ read ]
David E. Colmenero and Alex J. Pilawski discuss some situations where the Texas Comptroller's so-called "5% test" may result in a tax assessment and potential grounds that may call into question the legitimacy of its application.
The Lump-Sum Versus Separated Dilemma in Texas Sales and Use Tax... [ read ]
David E. Colmenero and Alex J. Pilawski explain the differences between lump-sum and separated contracts and their potential implications for Texas sales and use tax purposes with disputes between auditors and taxpayers.
IRS and DOJ Cracks Down on "Tribal Tax Credit" Scam: What You Need to Know... [ read ]
Joel N. Crouch examines the IRS and DOJ's ongoing criminal investigation into the so-called "Tribal Tax Credit" scheme. He delves into how promoters marketed these alleged credits as legitimate, only for taxpayers to face IRS disallowances, penalties, and lawsuits.
Equitable Tolling Opens the Tax Court Door: The Impact of Oquendo v. Commissioner... [ read ]
Joel N. Crouch examines the Sixth Circuit's recent decision in Oquendo v. Commissioner and its impact on the long-standing 90-day Tax Court petition deadline.
Employee Retention Credit (ERC) Examinations Surge... [ read ]
Jeffrey M. Glassman examines the IRS's intensified examinations surrounding Employee Retention Credit claims and how businesses can best prepare for heightened scrutiny.
How a BBA Partnership Representative Can Ruin Your IRS Audit... [ read ]
Nick S. Pegelow explores the risks partnerships face under the Bipartisan Budget Act (BBA)'s Centralized Partnership Audit Regime, and highlights the role of Partnership Representatives.
