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Tag: Civil Tax Controversies & Trials

The State of the Tax Whistleblower Law

By Usman Mohammad and Ashley Morales ABA Tax Times June 2023 Internal Revenue Code section 7623(b) provides mandatory awards to whistleblowers who provide information to the IRS that results in the collection of additional tax, interest, penalties or fines from corporations, high net worth individuals, and other entities. The statute

Christopher Ferguson Moderates A Panel Titled “Employee Retention Credit Audits And Investigations – The Tsunami Is Coming” At The 2023 NYU Tax Controversy Forum

On June 8, 2023, Christopher Ferguson moderates a panel titled “Employee Retention Credit Audits and Investigations – The Tsunami is Coming” at the 2023 NYU Tax Controversy Forum. Description: ​Claims for Employee Retention Credits (“ERCs”) have proliferated exponentially. Almost everyone has seen a commercial or received a text or email

What CPAs Need To Know About Employee Retention Credit Fraud

By Christopher M. Ferguson and David Taylor The CPA Journal March/April 2023 Most taxpayers have likely received a solicitation recently claiming that they may be entitled to thousands of dollars in employee retention tax credits. The solicitations involve the Employee Retention Credit (ERC), a payroll tax credit created by the

Andrew Weiner Moderates A Panel Titled “The Administrative Procedure Act v. The IRS: Which Regulations, Rules, And Notices Will Survive?” At The NYU Tax Controversy Forum

On June 8, 2023, Andrew Weiner moderates a panel titled “The Administrative Procedure Act v. The IRS: Which Regulations, Rules, And Notices Will Survive?” at the NYU Tax Controversy Forum. Description: Ever since the Supreme Court rejected tax exceptionalism in Mayo Foundation v. United States, 562 U.S. 44 (2011), challenges