Resources

In a rare win for a taxpayer, a federal district court in Idaho turned down an IRS request to enforce third-party summonses for information and granted the taxpayers’ motion to quash the summonses. The court said the IRS...

The tax treatment of compensation to S-Corp owners has reared its head again in an August 11th report issued by the Treasury Inspector General for Tax Administration (TIGTA).   As long as I have practiced...

Whether to implement a reincorporation of an S corporation, from say California to Texas, or to pave the way for an S corporation asset sale to a buyer taxed as a partnership, an F reorganization can be a tax efficient tool...

I’ve been practicing tax law for more than 30 years helping businesses and individuals resolve disputes with the IRS and I can’t tell you how many times a new client has complained about how they were mistreated by the...

Trying to work out a client’s IRS issues these days can be frustrating for the client and the tax professional. You can’t throw a stone without hitting a story about delays and problems the IRS is having. I was recently...