Resources

Josh Ungerman was quoted in the article, Siri Bulusu, Tax Cheats Face Higher Penalty for Hiding Assets From IRS, Issue 231, DTR (2018).

Josh Ungerman was quoted in the article, Siri Bulusu, Palantir Deal May make IRS ‘Big Brother-ish’ While Chasing Cheats, Issue No. 222, DTR (2018).

The Tax Court has recently adopted amendments to its Rules of Practice and Procedure. See here.  These amendments come more than two years after the Tax Court proposed amendments to its rules to accommodate...

On November 20th, the IRS issued Memorandum LB&I-09-1118-014 (here) updating the process for both domestic and foreign voluntary disclosures. The IRS voluntary disclosure program is found in section 9.5.11.9 of the...

How a taxpayer or tax professional reacts and responds to a visit by IRS criminal investigators may mean the difference between a criminal indictment and the IRS declining to pursue a criminal case. A taxpayer usually learns...