On January 19, 2017, the Texas Third Court of Appeals (the “Court”) in Agri-Plex Heating and Cooling, LLC v. Hegar found that a business buyer may not be able to escape successor liability for hidden tax...
IRS Launches New Audit Initiatives Targeting 13 Specific Tax Issues
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...
An Update on the Uncertain Fate of the Proposed Section 2704 Regulations
Before they were released in August of last year, we all knew the proposed regulations under section 2704 were going to be controversial. What we didn’t know back then was that Donald Trump was going to be...
IRS Injured Spouse Relief Provisions
Last year the Treasury Inspector General For Tax Administration (TIGTA) issued a report on the IRS track record in injured spouse cases. The full report is here. Although similar to the more well-known innocent spouse...
Payroll Taxes, Worker Misclassification and Options for Resolving IRS Audits
Employment taxes and worker misclassification continue to be priorities for the IRS and the Tax Division of the Department of Justice. The IRS has announced information sharing agreements with the Department of Labor and...