By Henry Stow Lovejoy CPA Journal April 2018 Edition The Internal Revenue Code (IRC) imposes penalties on understatements of tax as a way to encourage voluntary compliance and deter noncompliant behavior. Generally, the revenue agent examining a return will be one who proposes a penalty. Revenue
By Caroline Rule The Tax Lawyer In 1976, in Fisher v. United States, the Supreme Court first recognized the “act of production privilege” as being a necessary component of the Fifth Amendment’s privilege against self-incrimination. A grand jury subpoena or Service summons does not violate the Fifth
By Ian Weinstock The CPA Journal March 2018 Edition When advising taxpayers or preparing returns, brightline rules are generally the easiest to explain and to handle. In contrast, tax outcomes that depend on facts and circumstances are inherently more difficult to evaluate. It is therefore a relief
By Jerald David August Reprinted From The Winter 2018 Issue Of ALI-CLE’s The Practical Tax Lawyer Winter 2018 Edition On December 22, 2017, President Trump signed into law the Tax Cuts and Jobs Act (“TCJA”) of 2017, P.L. 115-97, which introduced a set of tax cuts and
By Wendy Abkin, George Abney, and Caroline D. Ciraolo Tax Executive Institute February 2018 TO DISCLOSE OR NOT TO DISCLOSE, THAT IS THE QUESTION Hamlet’s thoughts weighed heavily upon him. Should he suffer the slings and arrows of outrageous fortune, or take arms against a sea of
By Megan L. Brackney Law360 January 2018 The U.S. Treasury Department recently issued an interim rule to improve the Internal Revenue Service’s ability to identify contractors who have delinquent federal tax liabilities. Contractors should review their filing histories and recent returns to make sure they are
