Each year, the IRS identifies a dozen transactions — inclusive of scams, structured transactions, and other transactions that the IRS just doesn’t like – and puts them on its so-called “Dirty Dozen” list. Much...
Managing Partner, Anthony Daddino was quoted in a March 13, 2023 Tax Note article written by Kristen A. Parillo
March 14, 2023
Managing Partner, Anthony Daddino was quoted in a recent Tax Notes article written by Kristen Parillo on March 13, 2023 titled, “Limited Partner Status Requires Functional Analysis, IRS...
Part Three: Are Tax Returns Given to an IRS Agent Considered Filed?
March 14, 2023
By Joel N. Crouch, Blog
Last June, I wrote a blog post on a 9th circuit panel opinion in Seaview Trading LLC v. Commissioner, where the panel, in a 2-1 decision, reversed the Tax Court on the meaning of a “filed” return. The panel...
ERC: Is the IRS Trying to Ski Uphill?
March 8, 2023
By Joel N. Crouch, Blog
One of my favorite things to do is snow ski. I’ve been doing it for a long time and try to go on a couple of ski trips every year. In fact, I just returned from a trip with a couple of friends including my colleague Alan...
Josh Ungerman was quoted in an article by Andrew Velarde in Tax Notes on March 1, 2023
March 3, 2023
Firm Partner, Josh Ungerman was quoted in a recent Tax Notes article written by Andrew Velarde, “Supreme Court Hands Huge Victory to Non-Willful FBAR Violators” regarding the Supreme Court decision in the...