By Caroline Rule The CPA Journal October 2016 Edition Will the Fifth Circuit Clarify the IRS’s Burden of Proof? District courts and other authorities disagree on whether the IRS must prove willfulness by a preponderance of the evidence or by clear and convincing evidence when seeking
By Megan L. Brackney Journal of Passthrough Entities September – October 2016 Edition In my last column, I discussed the IRS’s prerogative to change its mind—to approve of a tax reporting position in one year, and then assess penalties on the ground that the taxpayer was
By Kevin M. Flynn The CPA Journal September 2016 Edition Filing a claim for refund of overpaid tax invoices much more than just submitting an amended return to the IRS with an explanatory statement that more than the correct amount of tax was paid. The refund
By Jerald David August Journal of Tax Practice & Procedure August – September 2016 Edition The Bipartisan Budget Act of 2015, which President Obama signed into law on November, 2015, repealed the complex and much-criticized TEFRA partnership entity-level audit (ELA) rules, including the electing large partnership
The Bipartisan Budget Act of 2015, which President Obama signed into law on November, 2015, repealed the complex and much-criticized TEFRA partnership entity-level audit rules, including the electing large partnership rules. On December 18, 2015, Congress passed, and President Obama signed into law, the Protecting
By Michael Sardar The CPA Journal July 2016 Edition It is not often in life that one is able to hit pause, rewind, and redo something that has already happened. To many taxpayers’ surprise, however, taxes are just one such area. Knowing the various options for
Thank you for attending the presentation, “How to Determine the Right Path Forward for Taxpayers with Foreign Asset Non-Compliance” by Michael Sardar For future reference please feel free to access the course materials on this web page to review or save. View or download course
By Brian P. Ketcham The CPA Journal June 2016 Edition Most CPAs are by now familiar with the IRS’s heavily publicized Offshore Voluntary Disclosure Program (OVDP), which allows taxpayers with previously undeclared foreign assets to file amended tax returns and delinquent information returns in exchange for
By Megan L. Brackney Journal of Passthrough Entities May-June 2016 Edition It is the IRS’s prerogative to change its mind. The IRS can conclude the audit of one tax year with no change and then make adjustments in a later tax year on the exact same
