Many taxpayers have begun to receive a letter from the IRS stating that the IRS intends to contact other persons—including potentially the taxpayer’s neighbors, banks, employers, and employees—about the taxpayer’s tax...
Interest on a federal tax liability generally begins accruing from the date the tax should have been paid, even when the additional tax is due to IRS examination changes. IRC Section 6404 allows the IRS to abate interest...
In prior blog posts (here) and (here), I discussed the application of the IRC Section 6651 failure-to-file penalty to an electronically-filed tax return. On August 2nd, a U.S. District Court in Tennessee took on the issue...
Expert testimony in litigation is very important. It is even more important in an estate tax case where the only issue is the value of the decedent’s assets and the case will likely turn on valuation expert testimony. ...
The Texas Comptroller’s office issued a draft set of proposed revisions to Comptroller Rule 3.586 (Margin: Nexus) today in response to the U.S. Supreme Court’s decision last year in South Dakota v. Wayfair, Inc., 138...
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