While the IRS has refused any formal program for late penalty relief, informally the IRS is embracing the virtue of forgiveness, with the magic word being “COVID-19.” In June 2020, the AICPA penned a letter to Treasury...
For the many businesses that secured a potentially forgivable loan under the Paycheck Protection Program (PPP), one of the more pressing issues is whether to apply for forgiveness now or later and the tax implications of...
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...
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