February 19-21, 2025
Mr. Ungerman’s experience as a former IRS Senior Trial Attorney and Department of Justice (DOJ) Special Assistant U.S. Attorney are invaluable in helping clients with IRS civil tax and criminal tax controversy matters at all levels along with tax and estate planning. The tax and estate matters in which Josh is involved are typically very complex from both a factual and legal perspective. These matters often require legal and accounting skills. Josh is also a Certified Public Accountant.
Mr. Ungerman is involved in defending Taxpayers & issues against IRS inquiries and actions. The IRS defense practice covers Civil and Criminal Exams, Investigations and Trials. Many of Josh’s Tax Controversy matters include an offshore component.
Mr. Ungerman is often called upon to remediate non-compliant offshore structures and advise on offshore compliance requirements.
Mr. Ungerman is selected to many “Best of” attorney lists by his peers including: Best Lawyers, D Magazine and Texas Monthly. Mr. Ungerman has been recognized by the Best Lawyers® in America as the 2023 Litigation and Controversy-Tax Law "Lawyer of the Year" in the Dallas/Fort Worth area. He was also selected to the Texas Super Lawyers Top 100 Lawyers list.
Prior to joining the firm in 1994, he was a civil prosecutor for the Internal Revenue Service, Dallas District Counsel office. He was also a Special Assistant United States Attorney for the Department of Justice in Dallas during his time as a civil prosecutor. Prior to becoming an IRS Attorney of a Special Assistant U.S. Attorney, he served as a law clerk to the Honorable Carolyn M. Parr at the United States Tax Court in Washington, D.C.
Josh is a frequent speaker on tax topics including domestic and offshore IRS exams, IRS estate tax strategies, tax shelter defense, recent tax legislation, IRS criminal tax investigation techniques, state tax controversy issues and IRS offshore compliance issues.
Mr. Ungerman was admitted to practice in Texas in 1990.
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- Southern Methodist University School of Law, J.D., 1990
- Board of Editors, Southwestern Law Journal
- University of Texas at Austin, B.B.A., 1987
- Dallas Bar Association
- Past Chair, Tax Section
- State Bar of Texas
- Past Chair, Tax Controversy Committee
- American College of Tax Counsel
- Fellow
- American Bar Association
- Member, Appointments to the Tax Court Committee, Tax Section, 2015-2017
- Past Chair, Civil and Criminal Tax Penalties Committee, Tax Section
- Past Chair, IRS Investigations and Practices Subcommittee, Tax Section on Civil and Criminal Tax Penalties
- American Institute of Certified Public Accountants
- Texas Society of Certified Public Accountants
- Dallas CPA Society
- Tax Committee
- New York University School of Continuing and Professional Studies
- Planning Committee Member, 2nd Annual Tax Controversy Forum
- UCLA Extension, Business, Management, and Legal Programs
- Planning Committee Member, 25th Annual Tax Controversy Institute
- Texas Super Lawyers-Tax as listed in Texas Super Lawyers Magazine and Texas Monthly, 2003 through 2024
- Texas Super Lawyers, Top 100 Lawyers in Texas list, 2017
- The Best Lawyers in America® 2023, Litigation and Controversy-Tax Law "Lawyer of the Year" in the Dallas/Fort Worth area.
- The Best Lawyers in America®, 2015-2025, Litigation and Controversy-Tax and Tax Law
- 2013 Top Rated Lawyer in White Collar Criminal Defense Law by ALM as published in The American Lawyer, Corporate Counsel & The National Law Journal, October 2013
- Best Lawyers, D Magazine's Hall of Fame, 2022, Tax: Litigation
- Best Lawyers in Dallas, D Magazine, 2008 and 2011, Taxation: 2012, 2015-2016 and 2018-2024 (Tax: Litigation)
- Best Business Lawyers, D Magazine, 2009: Tax
- Best Lawyer Under 40, D Magazine, 2004 and 2005
- Congratulations to Josh Ungerman for his five-year appointment to the American Bar Association Section of Taxation’s Committee on Appointments to the Tax Court ending June 30, 2023
Experience
- Civil Prosecutor, Internal Revenue Service, Dallas District Counsel office
- Special Assistant United States Attorney, Department of Justice, Dallas
- Law Clerk, Honorable Carolyn M. Parr, United States Tax Court, Washington, D.C.
Quotes:
- Mr. Ungerman was quoted in the Wall Street Journal articled published on March 29, 2024 by Laura Saunders titled, "How a 'Gorgeous' Dior Bag Cost a Widow $61,000 in Tax Court."
- Mr. Ungerman was quoted in the Bloombrg Law article published on February 28, 2024 by Chris Cioffi titled, "IRS Chief Counsel Nominee Heading to Senate Nod, Big Tasks Ahead."
- Mr Ungerman was quoted in the Bloomberg article, "HiLL TAX BRIEFING: Taxes in Focus Heading Into First 2020 Debate," by Colin Wilhelm, Kaustuv Basu and Patrick Ambrosio on September 29, 2020.
- Mr. Ungerman was quoted in the Tax Analysts article, "Taxpayers’ FBAR Fifth Amendment Gambit Fails," by Andrew Velarde on September 16, 2020.
- Mr. Ungerman is quoted in the TaxNotes article, "Appraiser Accuses IRS, DOJ of Violating Taxpayer Privacy Rules," by Kristen A. Parillo on December 30, 2019.
- Mr. Ungerman is quoted in the Tax Analysts article, "Practitioners See Potholes on Rettig's Road to Sentencing Court," by Nathan J. Richman on November 13, 2019.
- Mr. Ungerman is quoted in the TaxNotes article, "First Charges Announced for Bad Entry Into OVDP Alternative," by Nathan Richman on August 28, 2019.
- Mr. Ungerman is quoted in the TaxNotes article, "Stakes Rising in Litigation of Non-Willful FBAR Violations," by Andrew Velarde on August 1, 2019.
- Mr. Ungerman is cited in The 9th Circuit on opinion in Altera Corporation, The White Paper: The Stealth Bomber of the Section 482 Arsenal, 42 Sw. L.J. 1107, 1128-29 (1989) on June 7, 2019.
- Mr. Ungerman is quoted in the Wall Street Journal article, "The $26 Million Question: What Happens if You Don't File Your Taxes for a Decade?," by Laura Saunders on April 5, 2019.
- Mr. Ungerman is quoted in the Tax Analysts article, "More Marinello Uncertainties Rising to the Surface," by Nathan J. Richman on March 1, 2019.
- Mr. Ungerman is quoted in the Bluebook article, "Federal Court Upholds Maximum Penalty for Willful FBAR Violation," by Ryan Finley on January 3, 2019.
- Mr. Ungerman is quoted in the article, "Tax Cheats Face Higher Penalty for Hiding Assets From IRS," by Siri Bulusu on December 6, 2018.
- Mr. Ungerman is quoted in the article, "Palantir Deal May make IRS ‘Big Brother-ish' While Chasing Cheats," by Siri Bulusu on December 6, 2018.
- Mr. Ungerman is quoted in the TaxNotes article, "Constructive Knowledge Not Enough for FBAR Willfulness," by Andrew Velarde on September 11, 2018.
- Mr. Ungerman is quoted in the TaxNotes article, "Court Finds FBAR Penalty Can Exceed $100,000," by Kristen Parillo on September 11, 2018.
- Mr. Ungerman is quoted in the TaxNotes article, "IRS Using Data Analytics and New Unit to Sift 1 Billion Records," by Nathan Richman on June 26, 2018.
- Mr. Ungerman is quoted in the Bloomberg Law article, "Pharma CEO ‘Reckless’ in Not Disclosing Swiss Account: Government," by Matthew Beddingfield on April 27, 2018.
- Mr. Ungerman is quoted in the TaxNotes article,"Taxation of Bitcoin, Its Progeny, and Derivatives: Coin Ex Machina," by Stevie Conlon, Anna Vayer and Robert Schwaba on February 19, 2018.
- Mr. Ungerman is quoted in the TaxNotes article,"Kim Sentence Leaves Questions About FBAR Guideline Shift," by Nathan Richman on February 12, 2018.
- Mr. Ungerman is quoted in the TaxNotes article,"FOIA Request Nets Six More OVDP CHIEF Counsel Memos," by Andrew Velarde on January 23, 2018.
- Mr. Ungerman is quoted in the TaxNotes article,"Judge Vastly Narrows Summons on Coinbase Bitcoin Exchange Users," by Emily Foster on December 1, 2017.
- Mr. Ungerman is quoted in the TaxNotes article,"FOIA Request Yields 3 OVDP CHIEF Counsel Memos," by Andrew Velarde on November 21, 2017.
- Mr. Ungerman is quoted in the TaxNotes article,"IRS Involvement in Mueller Probe May Not Be About Taxes," by Nathan Richman on September 11, 2017.
- Mr. Ungerman is quoted in the TaxNotes artilce, "Are Public Leaks Enough for the Higher U.S. OVDP Penalty?," by Nathan Richman on August 21, 2017.
- Mr. Ungerman is quoted in BNA's Daily Tax Report article, "Swiss Firm's Tax Pact Signal to U.S. Clients Hiding Money Abroad, White Collar Crime Report," by Alison Bennett on August 18, 2017.
- Mr. Ungerman is quoted in the TaxNotes article, "Manafort Raid Could Indicate Suspected FBAR Violations," by Stephanie Cumings on August 10, 2017.
- Mr. Ungerman is quoted in Tax Notes Today by Tax Analysts article, "Fairness and Transparency Still Problems for OVDP," by Andrew Velarde on January 15, 2015.
- Mr. Ungerman is quoted in a BNA Daily Tax Report article, "Julius Baer Decision Offers Little Safety For Hidden Swiss Accounts, Attorneys Say," by Alison Bennett and Daniel Pruzin on January 16, 2014.
- Mr. Ungerman is quoted in a BNA Daily Tax Report article, "Swiss Banks Under Pressure as Deadline Nears for DOJ Program to Find U.S. Accounts," by Alison Bennett on December 20, 2013.
- Mr. Ungerman is quoted in TaxNotes by Tax Analysts article, "Second Circuit Reverses Convictions of 2 Former E&Y Shelter Promoters," on November 30, 2012.
- Mr. Ungerman is quoted in Tax Notes by Tax Analysts article, "The IRS's Misguided Fraud Whodunit," by Jeremiah Coderon on October 1, 2012.
- Mr. Ungerman is quoted in the Daily Tax Report article, "Hackers Offering Romney's Tax Returns Face Serious Punishment if Caught," by William Hoffman on September 7, 2012.
- Mr. Ungerman is quoted in BNA's Daily Tax Report in an article titled, "Taxpayers Fear Disclosing Offshore Assets As Deadline Approaches, Practitioners Say," on August 15, 2011.
- Mr. Ungerman is quoted in TaxNotes by Tax Analysts article, "Applying Mayo, Federal Circuit Defers to Controversial Overstated Basis Regulation," by Jeremiah Coder on March 14, 2011.
- Mr. Ungerman is quoted in TaxNotes by Tax Analysts article, "Seventh Circuit Overturns Tax Court on Gross Income Omission," by Jeremiah Coder on January 31, 2011.
- Mr. Ungerman is quoted in the BNA Daily Tax Report, "IRS Withdraws 'John Doe' Summons Against UBS Over Tax Fraud Allegations," by Daniel Pruzin (Geneva) and Alison Bennett (Washington) on November 17, 2010.
- Mr. Ungerman is quoted in a Tax Practice article published by Tax Analysts, "IRS Undeterred After Tax Court's Intermountain Decision," on May 24, 2010.
- Mr. Ungerman is quoted in a Tax Practice article published by Tax Analysts, "IRS Help for Struggling Taxpayers Contrasts With Enforcement Push," on April 12, 2010,
- Mr. Ungerman is quoted in a Tax Practice article published by Tax Analysts, "Federal Circuit Overturns Penalty Determination in Jade Trading," on April 5, 2010.
- Mr. Ungerman is also quoted in an article published on Tax Analyst entitled, "Swiss Agree to Expedite Processing of 4,450 UBS Accounts Under Treaty Request," by David D. Stewart on August 20, 2009.
- Mr. Ungerman is quoted in the Bloomberg article, "Billionaire Tax Felon Says UBS Lied in Pledge to Report to IRS," by David Voreacos on June 9, 2009.
- Mr. Ungerman is quoted on moneylaundering.com entitled, "Uptick in Tax Evasion Disclosures Mean More Bank Investigations, Say Attorneys," by Matt Squire on November 5, 2008.
- Mr. Ungerman is quoted in the book, “The Cheating of America: How Tax Avoidance and Evasion by the Super Rich Are Costing the Country Billions–and What You Can Do About It," by Charles Lewis and Bill Allison and the Center for Public Integrity.
- "Being Prepared for an IRS Criminal Investigation Visit", Dallas Bar Association Headnotes, April 2023
- Mr. Ungerman published the article, "IRS Criminal Investigation 2017 Annual Business Report—Criminals Would Be Foolish to Mistake Declining Resources for a Lack of CI Commitment," 20 JOURNAL OF TAX PRACTICE & PROCEDURE 31–36 (August-September 2018).
- He published an article in the April 2016 issue (Volume 41, Number 4) in the Dallas Bar Association Headnotes on, "Summer Vacation in the Caribbean - Not so Fast."
- Mr.Ungerman published an article in the Fall 2014 issue of the Texas Tax Lawyer on, "Are Virtual Currencies Such as Bitcoin the Next Tool for Tax Evaders - The IRS is Watching and You Might Be Surprised What They See. “TEFRA Partnership IRS Controversies: Now That The TEFRA Partnership Exam Is Complete With An FPPA, What Is A Partnership To Do?," Forbes IRS Watch, July 22, 2013.
- He published an article, "A Practical Guide to the New Round of IRS Examinations," in the Fall/Winter 2012, (Volume 31, No. 3) of the Petroleum Accounting and Financial Management Jourrnal published by the Institute of Pertoleum Accounting at the University of North Texas.
- Alan K. Davis and Josh O. Ungerman published an article, "An Untaxing Year" in the December 20, 2010 Texas Lawyer, Vol. 26., No. 38.
- "Proposed Schedule Targets Uncertain Tax Positions", In-House Texas, (An ALM Publication), Volume 25, No. 48, March 1, 2010.
- "Government Loses Sham-Transaction Criminal Tax Case in the Virgin Islands", The American Bar Association, Criminal Justice Section Newsletter, Volume 17, Issue 3, Spring 2009.
- “The IRS is Regularly Auditing Taxpayers Again", Dallas Bar Association Headnotes, Volume 32, Number 11, November 1, 2008.
- “The IRS Is Looking For Non-Compliant Taxpayers With Foreign Interests: Is Your Taxpayer One Of Them?”, The Practical Tax Lawyer, Volume 22, Number 3, Spring 2008 (published four times a year by American Law Institute-American Bar Association Continuing Professional Education in cooperation with the ABA Section of Taxation).
- “Important Tax Controversy Developments”, Texas Tax Lawyer.
- “Voluntary Disclosure and IRS Attacks on Offshore Credit Cards”, Corporate Business Taxation Monthly.
- “When IRS Criminal Special Agents Show up at Your Client's Door", Dallas Bar Association Headnotes, Volume 29, Number 2, March 1, 2005.
- “Foreign Distrust: Cayman Island Crackdown Reveals IRS Concern”, Texas Lawyer
- “Texas Sales Taxes on Construction-Why Can’t Anybody Get It Right?”, Texas Tax Lawyer.
December 13, 2024
ABA Section of Taxation 41st Annual National Institute on Criminal Tax Fraud and 14th Annual National Institute on Tax Controversy... [ read ]
November 20, 2024
Estate Planning Council of North Texas... [ read ]
October 23, 2024
TXCPA Permian Basin CPE Expo... [ read ]
September 27, 2024
ABA Section of Taxation Virtual 2024 Fall Tax Meeting... [ read ]
August 19, 2024
TXCPA 2024 Summit... [ read ]
June 27, 2024
16th Annual NYU Tax Controversy Forum... [ read ]
May 23, 2024
TXCPA East Texas CPE Expo... [ read ]
December 8, 2023
ABA National Institute on Criminal Tax Fraud and Tax Controversy... [ read ]
October 25, 2023
TXCPA Central Texas Member's CPE Expo... [ read ]
September 14, 2023
Collin County Bar Association Corporate Counsel Section... [ read ]
September 7, 2023
ALI CLE IRS Audits of Tax-Exempt Organizations and Private Foundations... [ read ]
August 29, 2023
2023 Panhandle Chapter/TXCPA Tax Institute... [ read ]
August 20, 2023
TXCPA Summit 2023 Pre-Conference Workshop... [ read ]
June 8, 2023
15th Annual NYU Tax Controversy Forum... [ read ]
May 24, 2023
2023 Texas Bank and Trust - Longview, TX... [ read ]
May 17, 2023
2023 Texas Bank and Trust, Tyler, TX... [ read ]
March 23, 2023
Council of Petroleum Accountants Societies (COPAS) Meeting... [ read ]
December 13, 2022
ABA 39th Annual National Institute on Criminal Tax Fraud and Tax Controversy... [ read ]
September 7, 2022
40th Annual Course Tax Law 2022: Practicing Law in Uncertain Times-Webcast Replay... [ read ]
August 21, 2022
TXCPA CPE Summit 2022 Pre Conference Workshop... [ read ]
August 3, 2022
40th Annual Course Tax Law 2022: Practicing Law in Uncertain Times... [ read ]
June 24, 2022
14th Annual NYU Tax Controversy Forum... [ read ]
May 25, 2022
Texas Bank and Trust Taxation and Estate Planning Update for Professionals... [ read ]
May 10, 2022
Texas Bank and Trust Taxation and Estate Planning Update for Professionals... [ read ]
December 9, 2021
ABA 38th Annual Institute on Criminal Tax Fraud... [ read ]
November 19, 2021
IRS Representation Conference 2021... [ read ]
November 18, 2021
The Practice Management Group November Webinar... [ read ]
November 7, 2021
TXCPA Summit 2021... [ read ]
October 28, 2021
Texas Management Group (TMG) Conference... [ read ]
June 9, 2021
Tax Alliance Conference 2021... [ read ]
November 20, 2020
2020 IRS Representation Conference... [ read ]
January 28, 2020
Henry & Peters In-House Presentation... [ read ]
December 13, 2019
2019 ABA 36th Annual National Institute on Criminal Tax Fraud and 9th Annual National Institute on Tax Controversy... [ read ]
December 12, 2019
ABA 36th Annual National Institute on Criminal Tax Fraud and 9th Annual National Institute on Tax Controversy... [ read ]
December 6, 2019
2019 Stanley Johanson Estate Planning Workshop... [ read ]
November 5, 2019
21st Annual Meadows Collier Tax Conference... [ read ]
June4, 2019
2019 Tax Alliance Conference... [ read ]
May 22, 2019
Central Texas Chapter/TXCPA CPE Expo... [ read ]
January 11, 2019
2019 Northern District of Texas Bench Bar Conference... [ read ]
December 14, 2018
2018 ABA 35th Annual National Institute on Criminal Tax Fraud and 8th Annual National Institute on Tax Controversy... [ read ]
November 1, 2018
2018 Meadows Collier Annual Tax Conference... [ read ]
October 30, 2018
The Texas Family Office & High Net Worth Annual Conference... [ read ]
August 2, 2018
Fort Worth Chapter/TSCPA 2018 Tax Institute... [ read ]
June 22, 2018
10th Annual NYU Tax Controversy Forum... [ read ]
December 7, 2017
ABA 34th Annual National Institute on Criminal Tax Fraud... [ read ]
October 23, 2017
Hein & Associates National Tax Meeting... [ read ]
September 18, 2017
PLI's Basics of International Tax - September 18, 2017 in San Francisco, CA... [ read ]
July 26, 2107
AXA Advisors Seminar... [ read ]
July 26, 2017
2017 IRS Nationwide Tax Forums Seminar... [ read ]
July 18, 2017
PLI's Basics of International Tax - July 18, 2017 in New York... [ read ]
June 15, 2017
NYU Tax Controversy Forum... [ read ]
June 6, 2017
Tax Alliance Conference... [ read ]
May 23, 2017
Texas Bank and Trust Seminar... [ read ]
May 9, 2017
Texas Bank and Trust Seminar... [ read ]
May 4, 2017
Texas Association of CPAs... [ read ]
May 1, 2017
East Texas Chapter/TSCPA Spring CE Expo... [ read ]
December 8, 2016
33rd Annual National Instit. on Criminal Tax Fraud & the Sixth Annual National Institute on Tax Controversy... [ read ]
November 30, 2016
UT Law 2016 Taxation Conference... [ read ]
November 14, 2016
SMU Dedman School of Law... [ read ]
October 25, 2016
18th Annual Meadows Collier Tax Conference... [ read ]
September 19, 2016
PLI in New York and Califorina... [ read ]
July 19, 2016
PLI in New York and Califorina... [ read ]
June 14, 2016
Tax Alliance Conference... [ read ]
May 18, 2016
Civil and Criminal Employment Tax Enforcement Efforts - Employers Beware Live CLE Webinar & Teleconference... [ read ]
December 11, 2015
32nd Annual Natl Instit on Criminal Tax Fraud & 5th Natl Instit on Tax Controversy... [ read ]
November 3, 2015
2015 Meadows Collier Taxation Conference... [ read ]
June 5, 2015
NYU 7th Annual Tax Controversy Forum... [ read ]
May 19, 2015
Central Texas Chapter/TSCPA CPE Expo- Waco... [ read ]
May 19, 2015
"Surviving an IRS EO Audit"... [ read ]
January 15, 2015
"Circular 230: Oversight of the Tax Practitioner" "Hot Topics in IRS Audits and Investigations"... [ read ]
December 11, 2014
"Ask The Experts: Top Tips in Criminal Tax Cases"... [ read ]
November 7, 2014
"The Eggshell IRS Exam: Tips for Survival and Strategies for Success"... [ read ]
October 20, 2014
"The Eggshell IRS Exam: What to Do?"... [ read ]
August 28, 2014
"Foreign Asset Reporting Obligations to the IRS"... [ read ]
June 20, 2014
"IRS Small Business/Self-Employed Division Update"... [ read ]
June 10, 2014
"FBAR Update"... [ read ]
May 22, 2014
"Passive Activity and Hobby Loss Limitations: Withstanding an IRS Attack of Your Client's Outside Business Activities Under Sections 469 & 183"... [ read ]
May 15, 2014
"Health Care Fraud"... [ read ]
May 6, 2014
"Health Care Fraud"... [ read ]
April 23, 2014
"Fraud, Omissions, Errors and Missed Deadlines"... [ read ]
December 12, 2013
"Prosecution and Defense of a Klein Conspiracy"... [ read ]
December 10, 2013
"Business Owner/Individual Estate Planning"... [ read ]
November 19, 2013
"Civil and Criminal Penalty and Eggshell Audits"... [ read ]
November 6, 2013
"Trust Fund Recovery Penalty"... [ read ]
June 19, 2013
"Statutes of Limitations, Assessments, Abatements, and Claims for Refund"... [ read ]
June 12, 2013
"How to Manage Criminal Cases When CI Knocks on Taxpayer's Door"... [ read ]
June 7, 2013
"Criminal Investigation Division Update"... [ read ]
May 29, 2013
"What We Can Expect from the IRS in 2013"... [ read ]
May 8, 2013
"Panelists - Criminal Tax"... [ read ]
November 5-7, 2012
Speech Title TBA... [ read ]
October 17, 2012
"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]
September 21, 2012
"Managing IRS Audits"... [ read ]
August 28, 2012
"Estate Planning for Business Owners"... [ read ]
July 20, 2012
"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]
June 8, 2012
"Home Concrete, Mayo, and other TEFRA Substance"... [ read ]
May 17, 2012
"Compliance Issues for U.S. Partnerships with Foreign Partners and U.S. Partners with Foreign Partnerships"... [ read ]
May 16, 2012
"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]
May 8, 2012
"Making Ends Meet: Getting Paid Consistently and Ethically"... [ read ]
May 2, 2012
"Making Ends Meet: Getting Paid Consistently and Ethically"... [ read ]
February 9, 2012
"Uncle Sam is More Active Than Ever: IRS Exam and Collection... [ read ]
January 4, 2012
"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]
December 1, 2011
"The IRS "Wealth Squad": If You Don't See Them in LB&I; Get Ready for their Influence on SBSE"... [ read ]
November 17-18, 2011
"Recent Developments in Texas Taxation"... [ read ]
November 14, 2011
"Practical Suggestions and Traps to Avoid When Working with the IRS"... [ read ]
November 3, 2011
"Judgment Day: Preparing for a Visit from Uncle Sam"... [ read ]
October 22, 2011
"Get Ready for the Newest Specialized IRS Civil Agents: The SBSE Fraud/Bank Secrecy Act/Anti-Money Laundering Agent" (Moderator)... [ read ]
September 30, 2011
"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]
August 24, 2011
"How CPAs Get in Trouble with the IRS"... [ read ]
July 26-28, 2011
"Examination Representation 101" "Reporting Cash Transaction and Foreign Financial Accounts (FBAR)"... [ read ]
May 18, 2011
"Don't Give Up on Family Limited Partnerships (FLPs)" "Differences Between Aggressive Tax Planning and Tax Fraud" "The Legislative and Admi... [ read ]
May 4, 2011
"Don't Give Up on Family Limited Partnerships (FLPs)" "Differences Between Aggressive Tax Planning and Tax Fraud" "The Legislative and Administrat... [ read ]
March 2, 2011
"Evolution of an IRS Fraud Case"... [ read ]
December 9, 2010
"What is the IRS Doing to Us Next?"... [ read ]
December 6, 2010
"What is the IRS Doing to Us Next?"... [ read ]
December 2, 2010
"Hot Issues and Priorities in IRS Examination and Appeals" "What is the IRS Doing to Us Next?"... [ read ]
November 4-5, 2010
"Federal income Tax Update--Planning in an Uncertain Climate" "Estate Planning Update and Year-End Planning" "Evolution of an IRS Fraud Case"... [ read ]
November 1, 2010
"IRS Hot Topics, The 2010 HIRE ACT, Examination of Estate and Gift Tax Returns, Keeping Estate Planners Out of Trouble and The Evolution of an IRS Fraud Case"... [ read ]
October 15, 2010
"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]
October 6, 2010
"Keeping Estate Planners Out of Trouble"... [ read ]
September 25, 2010
"Civil Tax Penalty Abatements - Fact or Fiction"... [ read ]
August 26, 2010
"Hot IRS Topics"... [ read ]
May 26, 2010
"Transfer Tax Litigation and the Keller Decision" "No Estate Tax - Now What?" "Evolution of an IRS Fraud Case"- Longview... [ read ]
May 20, 2010
"Differences Between Aggressive Tax Planning and Tax Fraud"... [ read ]
May 12, 2010
"Transfer Tax Litigation and the Keller Decision" "No Estate Tax - Now What?" "Evolution of an IRS Fraud Case"- Tyler... [ read ]
February 23, 2010
"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]
January 23, 2010
"The IRS Wealth Squad - Holistic Taxpayer Analysis"... [ read ]
November 3, 2009
"The IRS is Engaging Taxpayers Again: From Examination to Investigation-What the IRS is Looking For and How to Respond"... [ read ]
October 21, 2009
"Liability and Disclosure Issues/Circular 230 and Code 7216"... [ read ]
October 01, 2009
"Preparing for and Defending the Examination of Estate and Gift Tax Returns"... [ read ]
September 26, 2009
"Trial Strategies in Complex Tax Prosecutions: Evidentiary and Procedural Challenges" and "Practical Considerations Involving Ongoing Voluntary Disclosures (of Offshore Accounts)"... [ read ]
September 9, 2009
"Circular 230: Best Practices"- Dallas... [ read ]
September 8, 2009
"Circular 230: Best Practices"- Dallas... [ read ]
July 6, 2009
"Sink or Swim: IRS Throws Out a Limited-Time Voluntary Disclosure Program as a Life Preserver to Taxpayers Treading in Shark-Infested International Waters"... [ read ]
May 27, 2009
Annual Taxation and Estate Planning Update for Professionals Seminar sponsored by Texas Bank and Trust-Tyler... [ read ]
May 20, 2009
Annual Taxation and Estate Planning Update for Professionals Seminar sponsored by Texas Bank and Trust-Longview... [ read ]
April 5, 2024
Hobby Loss and Ranches – An Overview of Section 183... [ read ]
If a taxpayer undertakes an activity with the objective of making a profit, the expenses related to the activity are generally deductible and any excess losses related to the activity can be utilized in future tax years (subject to applicable net operating loss limitations). If the activity is deemed to be subject to the "hobby loss rules" of Internal Revenue Code Section 183, however, the expenses and losses related to the activity are generally disallowed. Much to the chagrin of taxpayers in farm and ranching businesses, the IRS often comes in after the fact in an examination and makes a determination that the farm and ranching activity is not engaged in for profit and, thus, subject to the punitive hobby loss limitations. A well thought out and thorough challenge to an IRS examination is imperative.
November 17, 2023
The Form 8300 Hazards for Businesses and Practitioners... [ read ]
The IRS has recently increased their focus and examinations of businesses who deal in cash (or cash equivalents such as cashier's checks and money orders). These examinations have led to significant fines and penalties for these unsuspecting businesses. If the IRS discovers that a business is not properly reporting cash transactions on IRS Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, the associated fines and penalties can easily amount to hundreds of thousands of dollars.
January 4, 2023
The IRS Compounding Interest Rate is 7%: Should You Make a Deposit or Advance Payment Now?... [ read ]
The IRS will charge interest on any amount of tax ultimately due. For taxpayers wanting to stop the accrual of interest before the liability is paid, some or all of the proposed deficiency can be deposited or paid to the IRS while the controversy continues.
March 14, 2022
Supreme Court Asked to Weigh in on FBAR Penalty Circuit Split: Fifth or Ninth? Boyd or Bittner? Per Form or Per Account? Inquiring Minds Want to Know!!!... [ read ]
The Supreme Court passes on most of the cases it is invited to decide, but appellate court splits are often the key to a Supreme Court opinion. Following the 5th Circuit Court of Appeals holding in United States v. Bittner, there now exists a divide among the 5th Circuit and 9th Circuit in the determination of the penalty that can be levied by the IRS when a taxpayer non-willfully fails to report offshore accounts on an FBAR. Mr. Bittner has requested that the Supreme Court settle the circuit court dispute.
December 3, 2020
IRS Doubles Down on Pursuing High Income Non-Filers... [ read ]
Eric Hylton, the commissioner of the IRS Small Business/Self-Employed Division, threw down the gauntlet December 3, 2020 with an article the IRS pushed out on the IRS Newswire on how the IRS views high income non-filers.
March 31, 2016
IRS Commissioner Makes Shocking Admission on the Effects of Congressional Budget Cutbacks - the IRS Will Lose $5 Billion in Tax Revenue Per Year... [ read ]
The IRS called the complicated tax plans offered by international accounting and law firms to their wealthy clients in the late 1990s and early 2000s "tax shelters". The IRS shut down that type of planning through aggressive enforcement and a revamping of the requirements for written tax advice. Since those "tax shelters" are long gone, it is disturbing that in March of 2016, IRS Commissioner Koskinen has admitted defeat to a $5 billion a year tax revenue loss.
January 7, 2016
IRS Criminal Employment Tax Enforcement: The Next Big Thing... [ read ]
The IRS has experienced a 28% decline in collectors from 2010 to 2014. Meanwhile, the IRS estimates that $59 billion is owed from unpaid employment taxes from which employment tax returns have been filed. Additionally, taxes withheld by employers make up two-thirds of IRS revenue collection by the IRS. These factors converge for the perfect storm of IRS Criminal Tax Enforcement on payroll taxes.
January 6, 2016
Spring Break in Mexico -- Think Again if you Owe the IRS... [ read ]
Was the Grinch in Congress last winter? The FAST Act, 2015 Fixing America's Surface Transportation Act, did much more than fix our nation's highways when enacted on December 5, 2015. The FAST Act broke down previous prohibitions that prevented the IRS from sharing information with the State Department.
October 21, 2015
IRS Announces it Has Raised $8 Billion Through its Offshore Remediation Programs While Conducting Thousands of Civil Offshore Exams and Numerous Criminal Offshore Investigations... [ read ]
On Oct. 16, 2015, the IRS announced that its offshore compliance programs have generated $8 Billion in IR-2015-116. More than 54,000 taxpayers have participated in IRS offshore remediation disclosure programs since 2009. The IRS warned taxpayers with non-compliant offshore accounts to "strongly consider existing paths established to come into full compliance with their federal tax obligations."
June 9, 2015
IRS and DOJ representatives made presentations at the NYU's Tax Controversy Forum in New York... [ read ]
On June 5th, a number of IRS and DOJ representatives made presentations at the NYU's Tax Controversy Forum in New York. The following were of interest.
June 4, 2015
How To Identify, Prepare For And Succeed In An IRS Eggshell Examination... [ read ]
Any IRS exam can be nerve-wracking experience for a tax advisor. If there is a large mistake or pattern of mistakes, an ordinary exam may become an eggshell exam requiring much thought and skill to come through the exam unscathed. This article will address the IRS exam areas that lead to IRS eggshell exams, the IRS tactics and, finally, steps a tax advisor can take to minimize the negative consequences.
