Resources

I’ve been practicing tax law for more than 30 years helping businesses and individuals resolve disputes with the IRS and I can’t tell you how many times a new client has complained about how they were mistreated by the...

Trying to work out a client’s IRS issues these days can be frustrating for the client and the tax professional. You can’t throw a stone without hitting a story about delays and problems the IRS is having. I was recently...

When a taxpayer does not agree with tax adjustments proposed by an IRS examiner, the IRS sends the taxpayer a Notice of Deficiency, which gives a taxpayer 90 days to file a petition with the U.S. Tax Court to dispute the...

On July 26th, U.S. Tax Court Judge Lauber issued an opinion in George S. Harrington v. Commissioner, upholding the IRS’ determinations that the taxpayer fraudulently underreported his offshore income and the civil...

In previous blog posts I have discussed the late filing penalty and the reliance on a tax professional defense to the penalty. We discussed the reliance defense with respect to a late estate tax return (HERE) and (HERE) and...