Partnerships are an enigma under federal tax law. Although the partnership files an annual income tax return (i.e., Form 1065), the partners report their allocable share of the partnership’s tax items on their income tax...
Category: Blog
Taxpayer Advocate Convinces IRS to Remove Willfulness Requirement for Voluntary Disclosure Program
June 25, 2025
Cooler minds prevailed: The Taxpayer Advocate convinced the IRS to ‘undo’ a recent, highly criticized change to the Voluntary Disclosure Program that required the taxpayer’s admission of willfulness prior to...
Proof That Dotting the I’s and Crossing the T’s Keeps the IRS at Bay
June 23, 2025
By Joel N. Crouch, Blog
I have given several presentations over the last few weeks to various professional groups about IRS procedures and representing clients in IRS controversies, including IRS examinations, appeals and litigation. In every...
At the outset, the IRS does not threaten tax-exempt status revocation whenever it examines a tax-exempt organization. But revocation should always be viewed as a possibility when the IRS enters the picture. Tax-exempt...
The IRS often challenges taxpayers who seek penalty abatements for late-filing penalties, particularly those related to international information returns. Generally, these cases focus on whether the taxpayer can...