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...
We previously discussed making a qualified settlement offer pursuant to I.R.C. Section 7430 to put pressure on the IRS and potentially collect attorneys’ fees and costs. How much does that offer need to be? In Mann...
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