I attended an informative panel discussion titled Challenging Revocations to Tax-Exempt Status at the ABA Tax Section’s Court Procedure and Practice Committee’s programming slot. Towards the end of the...
Category: Blog
The Good, the Bad, and the Ugly: The Impact of the Goverment Shutdown on Taxpayers and the IRS
October 20, 2025
By Joel N. Crouch, Blog
In the mid-1960’s there were a series of popular Western film, produced in Europe by Italian film makers that came to be known as “spaghetti westerns”. These films include “A Fistful of Dollars”, “For a Few...
Government Shutdown Could Require More ERC Lawsuits – And Form 907 May Offer No Relief
October 9, 2025
A federal government shutdown remains in place, and its effects are rippling through the IRS. For employers with pending Employee Retention Credit (ERC) refund claims — or those facing tight procedural deadlines — this is...
In 2024, the Supreme Court issued its decision in SEC v. Jarkesy, concluding that the SEC’s civil enforcement mechanism to collect a fraud penalty through administrative means violated the Seventh Amendment’s right...
FBAR Penalty Struck Down on Seventh Amendment Concerns
September 25, 2025
Under the Seventh Amendment of the U.S. Constitution, individuals generally have the right to jury trial in federal disputes. In 2024, the U.S. Supreme Court held in SEC v. Jarkesy that this constitutional right to...