According to an August 19th letter from Senate Finance Committee member Ron Wyden to SEC Chair Paul Akins, there is an ongoing Department of Justice and IRS criminal investigation regarding the sale of “alleged tax...
The recently formed 15th Court of Appeals, created by the Texas Legislature in 2023, has issued what appears to be its first decision involving a tax-related lawsuit and the Texas Comptroller. See Cao v....
When I first started my career as a tax controversy attorney one of the sacrosanct rules was that a Tax Court petition must be filed within 90 days of the date of the IRS Notice of Deficiency (NOD). If a petition...
The Internal Revenue Service has intensified its examination efforts related to Employee Retention Credit (ERC) filings, subjecting claims across the spectrum to heightened review and analysis. Current statistics reveal...
The world of syndicated conservation easements (SCEs) has been a hotbed of litigation in recent years, with the IRS aggressively challenging transactions it considers abusive tax shelters. One recent case, Silver Moss...
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