Resources

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 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...

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...

Josh Ungerman was quoted in the Tax Notes 2018 TNT 119-2 article, “Practitioners See Possible Pros and Cons in Fraud Program Changes.”