Resources

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...

The IRS has renounced its membership to the Green Day band fan club and finally restored due process in its procedures for assessing foreign gift tax return penalties. IRS Commissioner Danny Werfel publicly announced...