Resources

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...

When the IRS examines a tax return and proposes adjustments, it will send a Notice of Deficiency to the taxpayer setting forth the adjustments. A taxpayer who disagrees with the Notice of Deficiency may file a petition with...

The Internal Revenue Service has begun sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from those transactions or did not report them...

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...