On April 10, 2017, the IRS Chief Counsel’s Office issued an Action on Decision (AOD 2017-3) (here) refusing to acquiesce to the Tax Court’s and 9th Circuit’s decisions in Shea Homes Inc. v. Commissioner, 834 F.3d...
On April 3, 2017, Senators Jack Reed (D-RI) and Chuck Grassley (R-Iowa) introduced bipartisan legislation that may impact or deny tax deductions for settlement payments regarding corporate regulatory violations. In recent...
On March 30th, the Treasury Inspector General for Tax Administration (TIGTA) released a report titled “Criminal Investigation Enforced Structuring Laws Primarily Against Legal Source Funds and Compromised the Rights of Some...
On March 20th the U.S. Court of Appeals for the Second Circuit issued an opinion in Chai v. Commissioner that could impact every taxpayer who is disputing IRS penalties. A copy of the decision is here....
On March 21, 2017, the Treasury Inspector General for Tax Administration (TIGTA) issued a report entitled “A More Focused Strategy is Needed to Effectively Address Egregious Employment Tax Crimes” (here). The report...
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