Introduction Most federal tax disputes are resolved administratively or in the United States Tax Court, where taxpayers might challenge IRS determinations in a specialized forum that requires no prepayment of the disputed...
Congratulations to Six Meadows Collier Partners for their selection to The 2025 Inaugural Lawdragon 500 Leading Global Tax Lawyers. Lawdragon is extremely proud to recognize this talented and accomplished group of lawyers...
There are more than 100 penalties in the Internal Revenue Code. Each penalty varies in scope, but a common defense for almost all of them is “reasonable cause.” Where this defense applies, the IRS can’t impose...
Josh Ungerman is a contributing author of the article, “General Ethical Considerations for Tax Controversy Attorneys and Proposed Amendments to Circular 230–Implications for Tax Practitioners”, with C....
The IRS continues to struggle with processing and adjudicating ERC claims. Earlier today, Taxpayer Advocate published a Blog post with an update on the IRS’ progress (or lack thereof) and a call to the IRS to bring much...
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