In a previous blog post,(HERE), I discussed a case involving the liability of an executor for unpaid federal estate taxes. In this blog post, I will discuss the basics of transferee liability for a transferor’s taxes....
In an early 2019 blog post (here), we discussed the what and how of requesting an IRS Letter Ruling. The process for obtaining a Letter Ruling can be slow and time consuming and that has been further slowed by the pandemic....
On Monday, December 21, 2020, Stein and Corey Agee of Atlanta, Georgia entered guilty pleas in federal court to conspiracy charges related to their roles in syndicated conservation easement transactions. These are the first...
Eric Hylton, the commissioner of the IRS Small Business/Self-Employed Division, threw down the gauntlet December 3, 2020 with an article the IRS pushed out on the IRS Newswire on how the IRS views high income non-filers. If...
One of the tools in the IRS toolkit for limiting a taxpayer’s business and investment loss deductions is IRC Section 469 and material participation. In Gurpreet S. Padda and Pamela B. Kane v. Commissioner, the U.S. Tax...
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