I have given several presentations over the last few weeks to various professional groups about IRS procedures and representing clients in IRS controversies, including IRS examinations, appeals and litigation. In every...
At the outset, the IRS does not threaten tax-exempt status revocation whenever it examines a tax-exempt organization. But revocation should always be viewed as a possibility when the IRS enters the picture. Tax-exempt...
Congratulations to firm partner for his Josh O. Ungerman recognition a Highly Regarded Practitioner by ITR World Tax within Tax Controversy. ITR World Tax is the most comprehensive guide to the world’s leading tax...
The IRS often challenges taxpayers who seek penalty abatements for late-filing penalties, particularly those related to international information returns. Generally, these cases focus on whether the taxpayer can...
Grantor trusts are treated differently from other trusts for federal income tax purposes. Whereas many trusts are respected as separate entities for tax purposes, grantor trusts are disregarded with the grantor (or deemed...
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