Resources

Prior blog posts have discussed making voluntary disclosures to the IRS generally and for specific issues, such as offshore bank accounts, virtual currency and most recently the Employee Retention Credit. One thing we have...

In a blog post last year, Any Taxpayer Who Paid An International Information Return Penalty Should Consider Requesting a Refund, we discussed the Tax Court holding in Farhy v. Commissioner that the IRS does not have...

Yesterday the IRS announced updates to its strategic operating plan, which details how the IRS is spending billions of dollars from the Inflation Reduction Act (IRA). Spoiler alert – read the title of this Blog post. The...

For years, the IRS has offered alternative dispute resolution (ADR) at various stages of the tax administrative process. Use of ADR, however, has been declining in recent years. With this new office, IRS Appeals aims to make...

When the IRS issues a Notice of Deficiency (NOD), I.R.C. Sections 6212(a) and (b)(1) require that the NOD be sent to the taxpayer’s “last known address” by certified or registered mail. The taxpayer’s last known...