Early this year the U.S. Tax Court released a decision in Kelly v. Commissioner, which, among other things, discusses how a delinquent international return impacts the IRS statute of limitations for assessment. It is a...
Do you or your clients have an S corporation that you would like to convert to a limited partnership for tax purposes, but for the taxable gain thereon? Surprisingly, the Ways and Means tax proposals...
On September 13, 2021, the House Ways and Means Committee issued a series of proposals for consideration for the payment of the Biden Administration’s desired $3.5 Trillion infrastructure Bill. The final legislation will...
In an earlier blog post, I discussed the hidden danger of filing a Tax Court petition, i.e., that the IRS can raise new issues, including new penalties. In the case referenced in the prior blog post, Wegbreit v....
In a rare win for a taxpayer, a federal district court in Idaho turned down an IRS request to enforce third-party summonses for information and granted the taxpayers’ motion to quash the summonses. The court said the IRS...
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