In prior blog posts (here) and (here), I discussed the application of the IRC Section 6651 failure-to-file penalty to an electronically-filed tax return. On August 2nd, a U.S. District Court in Tennessee took on the issue...
Expert testimony in litigation is very important. It is even more important in an estate tax case where the only issue is the value of the decedent’s assets and the case will likely turn on valuation expert testimony. ...
In their article published by TXCPA entitled “Virtual Currency Holders Should Be Seeking Legal Counsel as IRS Begins Issuing Warning Letters,” David Colmenero and Anthony Daddino explore the IRS’ latest installment in...
The Texas Comptroller’s office issued a draft set of proposed revisions to Comptroller Rule 3.586 (Margin: Nexus) today in response to the U.S. Supreme Court’s decision last year in South Dakota v. Wayfair, Inc., 138...
Josh Ungerman was quoted in the Tax Notes article, “Stakes Rising in Litigation of Non-Willful FBAR Violations.” This article discusses whether the IRS can impose over $2.7 million in FBAR penalties for...
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