On July 11th, the 5th Circuit Court of Appeals heard arguments in Haynes v. United States regarding the application of a late filing penalty to an electronically filed tax return that was filed late due to a...
The IRS Large Business and International division – which serves corporations, subchapter S corporations, and partnerships with assets greater than $10 million – has announced a new series of targeted audits, referred to...
Josh Ungerman was quoted in the Tax Notes 2018 TNT 122-18 article, “ IRS Using Data Analytics and New Unit to Sift 1 Billion Records.” This article discusses the IRS Criminal Investigation using data analytics tools...
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 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...
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