If a taxpayer cannot resolve a dispute with either IRS examination or with the IRS Office of Appeals regarding tax and penalties, the IRS will send the taxpayer a Notice of Deficiency (NOD), sometimes referred to as a 90 Day...
In every recent IRS examination of a partnership and/or its partners in which I have been involved, the IRS has asked for information to support the computation of the partners’ basis in the partnership. It is critical...
The Trust Fund Recovery Penalty (TFRP) is a significant tool used by the Internal Revenue Service (IRS) to collect unpaid trust fund taxes. These taxes include amounts withheld from employees’ wages, such as income tax,...
Earlier this week the Senate confirmed Scott Bessent to serve as the next Treasury secretary by a vote of 68 to 29. Mr. Bessent is highly qualified to be the Treasury secretary and although he was easily confirmed, there was...
Sometimes IRS auditors make mistakes. Sometimes those mistakes need to be challenged administratively with the IRS Independent Office of Appeals (“Appeals”). And when the mistakes remain unresolved after Appeals...
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