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 centralized partnership audit regime is...
Please read the following article, “What the IRS Criminal Investigation Fiscal Year 2017 Annual Business Report Means for Tax Professionals and Taxpayers,” by Josh O. Ungerman, Issn. No. 1069-1553 INSIDE BASIS at...
Josh Ungerman was quoted in the Bluebook article, “Federal Court Upholds Maximum Penalty for Willful FBAR Violation.” Please click the link to read the article. Ryan Finley, Federal Court Upholds Maximum Penalty...
On December 20th, the IRS released Revenue Procedure 2019-9 providing guidance on whether disclosure of an item or position taken on a tax return is adequate for purposes of reducing or eliminating the Substantial...
Josh Ungerman was quoted in the article, Payroll Tax Collection Audits Are Dangerous Ground Now, 2018 TNT 242-7.
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