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Can a Taxpayer Avoid a Civil Fraud Penalty by Filing an Amended Tax Return?
By on June 26, 2018
In a prior blog post, we discussed amending a tax return to avoid the accuracy-related penalties. This blog post will discuss whether the same strategy can be used to avoid the civil fraud penalty under IRC Section 6663.
The Tax Court Hands the IRS Another Win in its Campaign Against Small Captive Insurance Arrangements
By on June 25, 2018
The IRS prevailed in another challenge against a small captive insurance arrangement in the case of Reserve Mechanical Corp. v. Comm'r, decided by the Tax Court on June 18, 2018. This is the second case decided in the IRS' favor involving a small captive, the first being Avrahami v. Commissioner decided last year. As the IRS seeks to build on these judicial victories, taxpayers would be well advised to look closely at their captive insurance programs to make sure they are not at risk for suffering the same fate as these taxpayers.
By on June 21. 2018
On June 21, 2018, the United States Supreme Court issued its opinion in South Dakota v. Wayfair, Inc., et al. In a 5-4 decision, the Court held a state can require out-of-state sellers with no physical presence in the state to collect sales tax on sales of goods or services delivered into the state.