For many years, the IRS has offered administrative pathways for taxpayers seeking to return to compliance with federal tax reporting obligations. These initiatives generally allow taxpayers to re-enter the reporting system...
Jeffrey Glassman was quoted in a Law360 article “Top Federal Tax Cases To Watch In 2nd Half of 2026”
July 6, 2026
In Kat Lucero’s recent Law360 article, “Top Federal Tax Cases To Watch In 2nd Half of 2026,” firm partner Jeffrey M. Glassman shares his perspective on a closely watched Employee Retention Credit (ERC) case....
The IRS continues to take an aggressive approach concerning reasonable cause relief associated with late international information returns. More recently, these attacks have centered on arguments that taxpayers do not...
Joe Rillotta coauthored an article with TaxNotes “Is the DOJ’s Dismantling of the Tax Division Illegal?”
July 1, 2026
In his latest article published with TaxNotes, “Is the DOJ’s Dismantling of the Tax Division Illegal?“, firm partner Joseph A. Rillotta, together with Carolyn Schenck and Jay Nanavati, examines the legal and...
$2.3m Penalty for a Swiss Bank Account Might be Excessive, Even When the Account Was Opened in the Name of the Taxpayer’s Dog
June 23, 2026
The IRS uses huge civil penalties as an aggressive enforcement weapon in the international arena, but an opinion issued by the U.S. Court of Appeals for the 11th Circuit reminds us that the government’s ability to punish is...