Firm Partner Joseph A. Rillotta wrote an article for Bloomberg Tax "Publix Heiress Tax Case Signals Continued IRS Supervisory Issues"

In his latest article published with Bloomberg Tax, "Publix Heiress Tax Case Signals Continued IRS Supervisory Issues," firm partner Joseph A. Rillotta examines a summons enforcement dispute that sheds light on IRS’s ongoing challenges in documenting required supervisory approvals. He highlights how an IRS auditor appeared to modify a summons after a supervisor signed off on it, resulting in a document "approved" before it was even prepared, and explains why this raises potential issues under United States v. Powell and other summons enforcement case law.