Josh Ungerman was quoted in the TaxNotes article, “Taxpayers’ FBAR Fifth Amendment Gambit Fails,” by Andrew Velarde on September 16, 2020.
Yesterday the IRS launched a new website for taxpayers and tax practitioners seeking information on the centralized partnership audit regime. As many of you will recall, in 2015 Congress exchanged one set of...
On August 17th, the Tax Court held in favor of the taxpayers regarding a $4 million charitable contribution deduction for donating land to a town in Emanouil v. Commissioner, T.C. Memo 2020-10. The IRS had challenged the...
As if the onslaught of recent losses in Tax Court was not enough, investors in syndicated conservation easements now have more to worry about. On August 25, 2020, the Senate Finance Committee released a bipartisan report...
As previously reported (Prior Blog Post), last summer the IRS sent letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax from those transactions or did not...
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