The IRS issued the eagerly awaited §199A proposed regulations on August 8, which will please some, but also leave others disappointed. Definition of Trade or Business As I discussed in an earlier blog post, since the §199A...
On July 11th, the 5th Circuit Court of Appeals heard arguments in Haynes v. United States regarding the application of a late filing penalty to an electronically filed tax return that was filed late due to a...
The IRS Large Business and International division – which serves corporations, subchapter S corporations, and partnerships with assets greater than $10 million – has announced a new series of targeted audits, referred to...
Josh Ungerman was quoted in the Tax Notes 2018 TNT 122-18 article, “ IRS Using Data Analytics and New Unit to Sift 1 Billion Records.” This article discusses the IRS Criminal Investigation using data analytics tools...
In a prior blog post, we discussed amending a tax return to avoid the accuracy-related penalties. This blog post will discuss whether the same strategy can be used to avoid the civil fraud penalty under IRC Section 6663....
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