This blog builds on prior posts concerning refund litigation. This blog explores the types of tax refund cases that can be brought in the U.S. district courts and the U.S. Court of Federal Claims. Types of Refund Litigation...
The application of U.S. tax laws often turns on the meaning of “residency.” Although U.S. citizens and residents are subject to federal income taxes on their worldwide income, non-residents who are not U.S. citizens...
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....
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