Statistics show that IRS Criminal Enforcement is down. But it is certainly not out. Seemingly adopting the mantra “quality not quantity,” earlier this year the IRS Criminal Investigations division announced the creation...
The Tax Court’s decision in Avrahami v. Commissioner created a storm that is brewing in the I.R.C. Section 831(b) micro-captive insurance industry. Some microcaptives are a safe distance away from the storm’s...
With funding and staffing low, and caseloads high, you would expect the IRS to be more attentive in its efforts to resolve cases. But in my experience the opposite holds true, with IRS personnel seemingly more interested in...
Whether due to oversight or intentional conduct, there are number of individuals and businesses with unfiled federal tax returns. Under the Internal Revenue Code (IRC) the failure to file a tax return is a misdemeanor (IRC...
The long, tumultuous road of the proposed regulations under I.R.C. Section 2704 (the “2704 Proposed Regulations”) should be coming to an end with Treasury’s recent report in response to Executive Order...
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