Resources

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...

One of my favorite things to do is snow ski. I’ve been doing it for a long time and try to go on a couple of ski trips every year. In fact, I just returned from a trip with a couple of friends including my colleague Alan...

When a taxpayer omits a foreign account from an FBAR form and that omission is nonwillful, federal law can still impose a steep monetary penalty. Originally that penalty was capped at $10,000, but the law requires that the...

In a prior blog post, HERE, I discussed how both the IRS Examination Division and the IRS Criminal Investigation Division were starting to focus on Employee Retention Credits (ERC) and ERC promoters. In a recent...