Most lawyers, especially those who handle some type of litigation, have warned clients about social media posts. Because people like to post pictures of events, extravagant trips and other adventures or discuss what they are...
On April 3rd the Tax Court issued an opinion in Farhy v. Commissioner, holding that the IRS does not have authority to assess certain international information return reporting penalties. As a result, any taxpayer...
The IRS issued Revenue Ruling 2023-02 on April 17, 2023, concluding that the basis adjustment incident to a person’s death, under Section 1014 of the Code, generally does not apply to the assets of a grantor trust unless...
Each year, the IRS identifies a dozen transactions — inclusive of scams, structured transactions, and other transactions that the IRS just doesn’t like – and puts them on its so-called “Dirty Dozen” list. Much...
Last June, I wrote a blog post on a 9th circuit panel opinion in Seaview Trading LLC v. Commissioner, where the panel, in a 2-1 decision, reversed the Tax Court on the meaning of a “filed” return. The panel...
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