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Generally, the IRS has three years to select an income tax return for audit. But if the taxpayer never files an income tax return, the three-year statute of limitations period never starts, providing the agency with unlimited...

  The Fifth Amendment to the United States Constitution provides that no person “shall be compelled in any criminal case to be a witness against himself.” Popularized in courtroom dramas—“I plead the...

For many professionals, the receipt of a federal grand jury subpoena may be the person’s first encounter with the federal government. If you’ve received a federal grand jury subpoena, take a breath—but don’t dismiss...

This is the second in a series of refund litigation blog posts. In this post, I focus on requirements that must be satisfied before a taxpayer can file a refund lawsuit. These initial requirements are more than just...

One of the most important questions a taxpayer must necessarily ask itself when performing work on real property is whether the work is an improvement to real property. The rules that apply to real property improvements for...