On January 6, 2017, the Texas Third Court of Appeals (the “Court”) withdrew their opinion and judgment in American Multi-Cinema, Inc. v. Hegar from April 30, 2015 to substitute a revised opinion (No....
On November 18, 2016 at the 2016 New England IRS Representation Conference in Ledyard, Connecticut, I had the honor of being on a panel discussion entitled Dealing with Non-filers. The panel covered a wide range of...
On December 2, 2016, the IRS issued final regulations outlining increased installment agreement entrance fees while adding a reduced fee for online payment agreements (click here to view the Federal Register which...
As the old adage goes, no good deed goes unpunished. In McClendon vs. United States, decided on November 17, 2016, the federal district court for the Southern District of Texas upheld the IRS’ trust fund penalty...
Last month, I blogged on the IRS’ identification of Code Section 831(b) micro captives as “transactions of interest,” which triggered an obligation by taxpayers and material advisors to formally disclose the details of...
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