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Navigating The Unsettled Listed Transaction Landscape

By Michael Waalkes The CPA Journal January 2024 Due to recent taxpayer-favorable court decisions requiring the Department of the Treasury to use formal notice-and-comment procedures under the Administrative Procedure Act (APA), the process by which the IRS publicly identifies listed transactions has undergone significant changes.

Making Your Case In Tax Court

By Abigail Burke ABA Tax Times Volume 43, No. 1 – Fall 2023 This article summarizes the tips for effective Tax Court advocacy presented in the ABA’s virtual CLE presentation titled “Making Your Case in Tax Court: Advocacy Tips.” […] Click here for the full

Covid Crooks Were No Match for IRS In Pandemic Fraud Task Force

By Don Fort Bloomberg Tax December 18, 2023 The Covid-19 pandemic brought about a once-in-a-generation health crisis, also creating a surge in fraud. Earlier this month, the IRS’s Criminal Investigation Division unveiled a conspicuously high conviction rate—over 98% for the more than 300 Covid-19 fraud

Navigating ERC Tax Audits and Investigations: Part One

By Christopher M. Ferguson CCH Journal of Tax Practice & Procedure Fall 2023, Volume 25, Issue 3 Over the past three and a half years, countless businesses have availed themselves of the Employee Retention Credit (“ERC”), a tax credit intended to incentivize businesses to retain

ChatGPT for Legal and Tax Professionals

By Garrett L. Brodeur, Grace Hall, and Ella Tynch CPA Journal September 2023 Since the introduction of ChatGPT in November 2022, artificial intelligence (AI) has taken the legal and accounting professions by storm. The use of AI in legal proceedings has already made headlines and research

Trump Cases Put the Crime-Fraud Exception in the Spotlight

By Sharon L. McCarthy and Daniel C. Davidson New York Law Journal September 15, 2023 “Attorney-client privilege is dead!” So declared then-President Donald Trump in a tweet after a 2018 law enforcement raid on his former lawyer Michael Cohen’s office. In fact, various investigations into

Payroll Tax Evasion Notice Suggests FinCEN’s New Focus

By Andrew Weiner and Jay R. Nanavati Law360 September 6, 2023 On Aug. 15, the Financial Crimes Enforcement Network within the U.S. Department of the Treasury issued Notice FIN-2023-NTC1 to advise U.S. financial institutions of the need to report payroll tax evasion and workers’ compensation