By Caroline Rule ABA Section of Litigation November 2017 Edition Most federal district court judges are accustomed – even in this age of “advisory” U.S. Sentencing Guidelines (Guidelines or U.S.S.G.) – to sentencing a criminal defendant by first calculating the applicable “Offense Level,” which provides for
By Kevin M. Flynn The CPA Journal November 2017 Edition Under Internal Revenue Code (IRC) section 6672(a), an individual can be held personally liable for a penalty for the willful failure to collect, account for, and pay to the IRS the employment taxes of a business.
By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure October – November 2017 Edition Taxpayers in a dispute with the IRS have a choice of forum in which to litigate. The Tax Court provides a pre-payment judicial review while taxpayers who pay in
By Jerald David August Journal of Passthrough Entities September – October 2017 Edition In McKelvey, the executor of the taxpayer’s estate petitioned for a redetermination of the $41.26M deficiency in income tax for 2008, processed by the IRS, attributable to his entering into various variable prepaid forward
Op-Ed By Bryan C. Skarlatos Featured on CNBC Crypto currencies may have been around for less than a decade, but they are proliferating so quickly that our established tax and regulatory systems can’t keep up. And that could create serious tax problems for those who would
By Jerald David August The CPA Journal October 2017 Edition Tax advisors of estates are generally aware that the executor or personal representative of the estate is personally liable for the payment of federal estate taxes not only with respect to the probate estate, but also
By Michael Sardar The CPA Journal September 2017 Edition Several years ago, the IRS started its successful takedown of secret Swiss banking with the use of a John Doe summons. Full Article
By Megan L. Brackney Journal of Taxation October 2017 Edition After a long period of inactivity, the IRS has recently released four notices identifying new reportable transactions. Full Article
By Megan L. Brackney Journal of Passthrough Entities September – October 2017 Edition If you are preparing, or advising on, the filing of amended returns or other claims for refund, one of the most important things to consider is the variance doctrine, and how it could
