In the recent case of Watts v. Comm’r, T.C. Memo. 2020-143, the Tax Court cited to the Danielson rule in holding for the IRS. So, what is the Danielson rule? The Danielson rule came...
Earlier today, the IRS announced a second time-limited settlement initiative for certain taxpayers under audit who participated in microcaptive insurance transactions. Only taxpayers who receive an offer...
I know what you are thinking: I can’t count letters. But the truth is far worse. The IRS used the five-letter “F” word: Fraud. The IRS recently released an IRS attorney memorandum addressing the...
I recently had one of those “aha” moments and thought it was blog-post worthy. A tax return preparer called me after a tax return he tried to electronically file was rejected by the IRS because a return had already been...
Lest we forget the IRS’ position on microcaptives, yesterday the IRS issued a reminder to taxpayers that they should consult an “independent tax advisor” to size-up their captive insurance planning because “any future...
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