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In a recent memorandum opinion, Om P. Soni v. Commissioner, T.C. Memo 2021-137, the U.S. Tax Court discussed a rule rarely seen in tax cases: the “tacit consent rule.” The court held that although the taxpayer’s...

Congratulations to Brian J. Spiegel! Click HERE to read the announcement..

The U.S. Tax Court recently issued two memorandum opinions regarding animal breeding activities and whether the taxpayers at issue could deduct expenses in excess of income from the activity. In Skolnick v. Commissioner,...

    The IRS recently issued Notice 2021-65, offering guidance to employer-taxpayers after the Infrastructure Investment and Jobs Act (“Infrastructure Act”) ended the employee retention credit for...

Perhaps you have noticed that it is often impossible to get through to the IRS on its Practitioner Priority Line. Lately, it has not been uncommon for the IRS to simply disconnect callers due to “extremely high call...