As in comedy, the most important element in an IRS voluntary disclosure is generally timing. However, a couple of U.S. Tax Court memorandum opinions in Whistleblower 14376-16W v. Commissioner, T.C. Memo...
One of my ERC friends sent me the IRS letter below that was received by one of his ERC clients about their ERC filing. The letter, Notice CP271, says there has been aggressive advertising involving ERC and the employer should...
According to the IRS, private jet usage by certain taxpayers just doesn’t fly. Today the IRS announced plans to initiate dozens of audits on business aircraft involving personal use. A copy of the announcement is...
As discussed in a previous blog post, the IRS generally has three years to assess additional tax, pursuant to IRC Section 6501. The three years can be extended by agreement, the taxpayer filing for bankruptcy, the IRS...
As more and more taxpayers consider filing lawsuits to receive an ERC refund, it is important to understand where the lawsuits can be filed. Before a taxpayer is legally allowed to file a refund lawsuit in court, taxpayers...
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