Mike Villa was quoted in the TaxNotes article, “New IRS Practice Unit Explains Penalty Relief,” by Kristen A. Parillo on July 10, 2020.
The IRS Publishes a Roadmap for Bipartisan Budget Act (BBA) Partnership Audits
On July 6th, the IRS published a BBA Roadmap for Taxpayers to assist partnerships subject to the centralized partnership audit regime. The centralized partnership audit regime was created in the Bipartisan Budget...
IRS Releases Practice Unit on Reasonable Cause and Good Faith Defenses to Penalties
On July 2, 2020, the IRS released a practice unit addressing a taxpayer’s reasonable cause and good faith defenses to civil penalties. IRS practice units are developed through internal collaboration and serve as both job...
Working With the New IRS Independent Office of Appeals
On July 1, 2019, the Taxpayer First Act was signed into law and among other things, it established the “Internal Revenue Service Independent Office of Appeals”. The IRS Office of Appeals has been around for almost 100...
In an unexpected development on June 25th, the IRS announced a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving syndicated conservation easement transactions. The...