Resources

When I first started my career as a tax controversy attorney one of the sacrosanct rules was that a Tax Court petition must be filed within 90 days of the date of the IRS Notice of Deficiency (NOD). If a petition...

The Internal Revenue Service has intensified its examination efforts related to Employee Retention Credit (ERC) filings, subjecting claims across the spectrum to heightened review and analysis. Current statistics reveal...

The world of syndicated conservation easements (SCEs) has been a hotbed of litigation in recent years, with the IRS aggressively challenging transactions it considers abusive tax shelters. One recent case, Silver Moss...

In a blog post last year, I discussed the Tax Court’s decision in Murrin v. Commissioner, T.C. Memo 2024-10. In Murrin, the Tax Court again held that indefinite statute of limitations for tax assessment...

Internet fraud continues to rise in the United States. In an unfortunately common scenario, a fraudster befriends an individual on social media, builds a rapport, and suggests an investment opportunity. In building...