Generally, spouses who file a joint return are subject to joint and several liability for tax deficiencies under the Internal Revenue Code.[1] Yet the IRS may grant a spouse relief from joint and several liability on a...
In a blog post last year (HERE), we discussed the parties’ oral arguments in the 5th Circuit Court of Appeal hearing in Haynes v. United States regarding the application of reasonable cause and a late filing...
New Partnership Audit Rules: Should the Partnership Agreement be Amended? In November 2015, as part of the Bipartisan Budget Act (BBA) of 2015, Congress enacted a new centralized Partnership Audit Rules (PAR) to replace the...
In November 2015, as part of the Bipartisan Budget Act (BBA) of 2015, Congress enacted a new centralized partnership audit regime to replace the TEFRA partnership rules. The new partnership audit regime applies to all...
The lifetime estate and gift tax exemption has risen more than 1600% over the past two decades. In 2017, with an exemption of $5,490,000, there were roughly 5,200 taxable estates but with an exemption of $11,180,000, that...
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