Resources

In a prior blog post, I discussed the burden of proof in a tax controversy and how in most situations, the taxpayer has the burden of proof. In this post, I will discuss how a taxpayer can shift the burden of proof to...

A search of the IRS website for “burden of proof” turns up the following statement: “The responsibility to prove entries, deductions, and statements made on your tax returns is known as the burden of proof. You must be...

In a prior blog post, here, we discussed some of the items of interest in the 2018 IRS Criminal Investigation Division’s 2018 Annual Report released in November 2018. In recent weeks, there have been a few additional...

Recurring problems with many S corporations include the untimely discovery of a failure to timely file an S election, filing of an inadvertently invalid election, or inadvertent termination of a previously valid S election....

How does one FBAR return filing give rise to 13 penalties? Ask the federal district court of California, which recently upheld the IRS’ imposition of separate non-willful penalties against 13 foreign accounts disclosed on a...