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The U.S. Supreme Court reversed a taxpayer’s conviction today under 26 U.S.C. § 7212(a), also known as the Omnibus Clause, which forbids “corruptly or by force or threats of force . . . obstruct[ing] or imped[ing],...

On March 13, 2018, the Internal Revenue Service (IRS) announced that it will terminate its 2014 Offshore Voluntary Disclosure Program (OVDP), effective September 28, 2018. Since its launch in 2009, over 56,000 taxpayers have...

In prior blog posts (here) and (here), we discussed IRS efforts to combat what it considers to be abusive conservation easement deductions. In Notice 2017-10 (here), the IRS warned that certain conservation easement...