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...
Significant changes are coming to Form 8867, Paid Preparer’s Due Diligence Checklist, and the associated requirements for the 2019 filing season. On November 5, 2018, the IRS issued final regulations under Treas. Reg. §...
Josh Ungerman published the article, “What to do When the IRS Shows Up at Your Client’s Door,” in the Dallas Bar Association Headnotes, December 2018, Volume 43, Number 12.
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