Firm partners Jeffrey M. Glassman and Matthew L. Roberts, through their respective leadership positions with the State Bar of Texas Tax Section (Tax Section), recently submitted comments to the Treasury and IRS...
Court Grants Taxpayers’ Motion for Summary Judgment on Proposed Civil Fraud Penalty
If a taxpayer cannot resolve a dispute with either IRS examination or with the IRS Office of Appeals regarding tax and penalties, the IRS will send the taxpayer a Notice of Deficiency (NOD), sometimes referred to as a 90 Day...
The IRS is Targeting Partnership Basis Computations
In every recent IRS examination of a partnership and/or its partners in which I have been involved, the IRS has asked for information to support the computation of the partners’ basis in the partnership. It is critical...
The Importance of Preparing a Well-Written Targeted Protest to Avoid Liability for a Trust Fund Recovery Penalty
The Trust Fund Recovery Penalty (TFRP) is a significant tool used by the Internal Revenue Service (IRS) to collect unpaid trust fund taxes. These taxes include amounts withheld from employees’ wages, such as income tax,...
New Treasury Secretary Scott Bessent and SECA Taxes
Earlier this week the Senate confirmed Scott Bessent to serve as the next Treasury secretary by a vote of 68 to 29. Mr. Bessent is highly qualified to be the Treasury secretary and although he was easily confirmed, there was...