For a multitude of reasons, the late-filing penalty has remained a priority of the IRS. First, the late-filing penalty is easy for the IRS to police through the use of modern computer systems which automatically identity and...
Author: Meadows Collier
Is That a Change in the Wind? The 6th Circuit Rules Against the IRS on the Application of the Substance-Over-Form Doctrine
February 20, 2017
By Joel N. Crouch, Blog
On February 16th, the Federal Court of Appeals for the Sixth Circuit issued a very entertaining and interesting opinion in Summa Holdings Inc. v. Commissioner, (HERE) holding that the taxpayers’ use of a Domestic...
On January 19, 2017, the Texas Third Court of Appeals (the “Court”) in Agri-Plex Heating and Cooling, LLC v. Hegar found that a business buyer may not be able to escape successor liability for hidden tax...
IRS Launches New Audit Initiatives Targeting 13 Specific Tax Issues
February 2, 2017
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...
An Update on the Uncertain Fate of the Proposed Section 2704 Regulations
January 31, 2017
By Meadows Collier, Blog
Before they were released in August of last year, we all knew the proposed regulations under section 2704 were going to be controversial. What we didn’t know back then was that Donald Trump was going to be...