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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

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By Jeffrey M. Glassman on November 19, 2024

Private Aircraft Audits May Be At Cruising Altitude... [ read ]

Earlier this year, the IRS announced that it would be increasing the audit rate on private aircraft. The IRS previewed that there would be dozens of private aircraft audits starting in the near future. Given what we have seen, the "dozens" figure appears low.

By Joel N. Crouch on November 13, 2024

Collecting Attorney's Fees and Expenses From the IRS... [ read ]

We previously discussed making a qualified settlement offer pursuant to I.R.C. Section 7430 to put pressure on the IRS and potentially collect attorneys' fees and costs. How much does that offer need to be? In Mann Construction Inc. v. United States, (E.D. Mich. 1/1/24), a district court said the offer can be as little as $1 for a prevailing taxpayer to collect attorneys' fees and expenses.

By Anthony P. Daddino on October 25, 2024

IRS Abandons Automatic Assessment of Foreign Gift Penalties... [ read ]

The IRS has renounced its membership to the Green Day band fan club and finally restored due process in its procedures for assessing foreign gift tax return penalties. IRS Commissioner Danny Werfel publicly announced yesterday that the IRS will no longer automatically impose penalties for late-filed forms related to foreign gifts.

By Jeffrey M. Glassman on October 23, 2024

Cryptocurrency Staking Clarity on the Horizon? If At First You Don't Succeed…... [ read ]

In February 2022, I wrote about the cryptocurrency staking case, Jarrett v. United States. At issue in Jarrett was whether particular cryptocurrency tokens (Tezos) created through staking should be considered taxable income. The taxpayers said the newly-created tokens were not taxable income, but the government took the opposite view

By Anthony P. Daddino on October 23, 2024

IRS Launches New Exam Unit Dedicated to Increasing Audits of Pass-Through Entities... [ read ]

I always enjoy life-imitating-art moments, especially when a 1970s Saturday morning cartoon is involved. Yesterday the IRS launched a new initiative: A Wonder-Twin-esque collaboration between small and large business divisions of IRS Exam specifically devoted to ensuring compliance of pass-throughs of every size and form—including partnerships, S-corporations and trusts. Unlike the Wonder Twins, the IRS' goal is not an octopus riding an ice unicycle, but rather, "to reverse historically low audit rates" for pass-through entities.

By Jeffrey M. Glassman on September 3, 2024

Appeals Court Rules: IRS Must Follow the Constitution Regarding FBAR Penalties... [ read ]

The Eighth Amendment of the U.S. Constitution provides that excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted. The IRS has for many years calculated penalties related to foreign bank and financial accounts that many rational thinkers would view as excessive. Yet, courts have generally not ruled that the IRS's FBAR penalties violated the Eight Amendment's Excessive Fines Clause. No more.

By Jeffrey M. Glassman on August 30, 2024

Beware the ERC Clawback: IRS May Recapture Tens of Thousands of ERC Refunds... [ read ]

On August 15, 2024, the IRS not only announced a second ERC Voluntary Disclosure Program (VDP), they also announced that this fall they would be mailing a large volume of letters ("up to 30,000") reversing previously-paid ERC refunds. The IRS anticipates that the clawback notices—commonly referred to as "recapture letters"—could represent more than $1 billion in claims. Businesses receiving such IRS recapture letters will be ineligible for the new ERC VDP, which provides an incentive for businesses to move quickly if they wish to participate in the ERC VDP.

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