On May 29, 2020, the Treasury Inspector General for Tax Administration (TIGTA) issued a report entitled,“High-Income Nonfilers Owing Billions of Dollars Are Not Being Worked by the Internal Revenue Service”. The report...
On May 29th, the U.S. Tax Court announced it will be conducting remote trial sessions until further notice, joining many other courts around the country. A short press release announcing remote trial sessions is HERE....
After a string of government victories in willful FBAR penalty cases, there may be some light at the end of the tunnel for taxpayers challenging an assertion of a willful FBAR penalty. In United States v. Sandra J. de...
As discussed in Part I of this series, the cancellation of indebtedness, whether in whole or in part, generally results in COD Income to a taxpayer which must be included in gross income. Section 108 of the Internal...
In a case with potentially broad implications, the Third Court of Appeals recently agreed with the Texas Comptroller that revenues received by a taxpayer from subscription-based satellite-radio programming could be sourced to...
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