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...
Can a Taxpayer Avoid a Civil Fraud Penalty by Filing an Amended Tax Return?
June 26, 2018
By Joel N. Crouch, Blog
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....
The Tax Court Hands the IRS Another Win in its Campaign Against Small Captive Insurance Arrangements
June 25, 2018
The IRS prevailed in another challenge against a small captive insurance arrangement in the case of Reserve Mechanical Corp. v. Comm’r, decided by the Tax Court on June 18, 2018. This is the second case decided in the...
U.S. Supreme Court Overturn’s Physical Presence Rule in Holding States Can Require Out-of-State Sellers to Collect Sales Tax
June 21, 2018
On June 21, 2018, the United States Supreme Court issued its opinion in South Dakota v. Wayfair, Inc., et al. In a 5-4 decision, the Court held a state can require out-of-state sellers with no physical presence in...