In February 2022, I wrote about the cryptocurrency staking case, Jarrett v. United States. A link to the prior blog can be found here. At issue in Jarrett was whether particular cryptocurrency tokens...
Category: Blog
Yesterday the IRS announced the processing of 400,000 ERC claims, with the vast majority being approved and totaling $10 billion. The question is: should taxpayers cash the checks or assess their options? For most taxpayers,...
ERC Update: More Time For Appeals to be Filed
On September 19, 2024, the IRS published a page to its website (link) with new and potentially helpful information about Employee Retention Credit (ERC) denial letters. The page is titled “Understanding Letter 105-C,...
The IRS Has Changed the Rules for a Voluntary Disclosure. Will Anyone File One?
When I first started practicing law in the late 1980’s the procedure for making an IRS voluntary disclosure was very simple and informal. The goal of a voluntary disclosure was to correct problems or file delinquent tax...
The Eighth Amendment of the U.S. Constitution provides that excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted. The IRS has for many years calculated penalties...