Resources

In tax controversy and litigation matters, sometimes procedure trumps the merits of a case. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS generally can’t...

We often find ourselves advising clients that Texas tax auditors and investigators are not their friends. Taxpayers can sometimes be lured into a false sense of confidence with a “friendly” auditor – that is, until they...

In a recent collection due process (CDP) case, Cade v. Commissioner, T.C. Memo 2025-20, the Tax Court reminded taxpayers what is required to establish a charitable contribution deduction. In Cade, the taxpayers...

Firm partners Jeffrey M. Glassman and Matthew L. Roberts, through their respective leadership positions with the State Bar of Texas Tax Section (Tax Section), recently submitted comments to the Treasury and IRS...

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...