A recent decision in by the U.S. Tax Court in Fine v. Commissioner, 167 T.C. No. 13(2026) is a good reminder about the IRS assessment statute of limitations (SOL) and the impact of agreements to extend the assessment...
Joel Crouch, Topic TBA Austin, TX
The IRS and Treasury recently issued Notice 2026-62, announcing increased scrutiny of certain sophisticated investment fund and tax-planning strategies. The notice focuses on transactions involving exchange-traded funds...
Land Donations To Charity If a client has ever told you they’re “just donating the land outright” to a charity or land trust — no easement, no strings attached — you may have breathed a sigh of relief. Fee...
Key Takeaways Overview A federal district court in North Texas significantly reshaped the FBAR litigation landscape in 2025 when it concluded that willful FBAR penalty assessments violated the Seventh Amendment right to a...
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