Resources

On February 16th, the Federal Court of Appeals for the Sixth Circuit issued a very entertaining and interesting opinion in Summa Holdings Inc. v. Commissioner, (HERE) holding that the taxpayers’ use of a Domestic...

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...

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...

  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...

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...