Resources

Each year, I enjoy participating in the ABA Tax Section’s Criminal Tax Fraud and Tax Controversy Conference in Las Vegas. (Just look at how happy I look in the picture below.) 2024 was no different. This year, I had the...

A December 2023 Gallup poll revealed that only 16% of Americans rate lawyers’ honesty and ethical standards as “high.” Perhaps the IRS was among those polled, as the IRS has announced an examination campaign against law...

I speak at a number of events during the year regarding tax issues, primarily regarding IRS enforcement and mostly related to income tax or estate and gift tax issues. Many of my presentations reference the IRS Dirty Dozen...

In a recent blog post I discussed a case where a taxpayer was in a dispute with the IRS, made a qualified settlement offer of $1 to the IRS, won the case and collected attorney fees and costs from the IRS under IRC Section...

Earlier this year, the IRS announced that it would be increasing the audit rate on private aircraft. The IRS previewed that there would be dozens of private aircraft audits starting in the near future. Given what we have...