On July 2, 2020, the IRS released a practice unit addressing a taxpayer’s reasonable cause and good faith defenses to civil penalties. IRS practice units are developed through internal collaboration and serve as both job...
On July 1, 2019, the Taxpayer First Act was signed into law and among other things, it established the “Internal Revenue Service Independent Office of Appeals”. The IRS Office of Appeals has been around for almost 100...
In an unexpected development on June 25th, the IRS announced a time-limited settlement offer to certain taxpayers with pending docketed Tax Court cases involving syndicated conservation easement transactions. The...
Modifying the terms of indebtedness, as opposed to cancelling or discharging the indebtedness, leaves the indebtedness outstanding but revises the terms governing the obligation. For example, the lender and borrower of a debt...
Just when you thought the IRS hit full speed in its enforcement campaign against microcaptives, the IRS found another gear. After pursuing captive management companies, tax advisors, and taxpayers alike, the IRS has set...
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