On June 22nd, the U.S. Tax Court released a memorandum decision in Kamal v. Commissioner, T.C. Memo 2023-80, which is a helpful reminder of what evidence a court will consider when the IRS has proposed a 75% civil fraud...
Jeffrey M. Glassman has been named Co-Chair of the 2023-2024 SBOT Tax Section’s Tax Controversy Committee at the Annual Meeting on Friday, June 16, 2023 in Dallas, TX. Mr. Glassman served as Vice-Chair of the Tax...
For employers who have either filed for or have received payment for Employee Retention Credit (ERC) claims, the significant surge in IRS examinations of ERC claims is similar to the shark in the movie Jaws. You know he is...
Employee Retention Credit (“ERC”) transactions. My colleagues’ previous blog posts described how the IRS has added Employee Retention Credit transactions to its annual “Dirty Dozen” list (link). We are now seeing...
On May 31, 2023, the California Franchise Tax Board (FTB) issued Notice 2023-02 providing a limited time settlement opportunity to taxpayers who participated in potentially abusive Micro-Captive Insurance (MCI) and...
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