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Tag: Civil Tax Controversies & Trials

2024 AML Partnership Forum

On March 19, 2024, Don Fort will be moderating a law enforcement panel at the AML Partnership Forum with IRS-CI, HSI, and FBI officials. He will also be delivering the closing remarks on Wednesday, March 20, 2024. The event is taking place this year from March 18-20, 2024 at the

Law360 Quotes Daniel C. Davidson On First Purely Tax Crypto Indictment

Daniel C. Davidson was quoted in a February 14, 2024 Law360 article titled “First Purely Tax Crypto Indictment Signals More On Tap” on the financial activities likely to capture the IRS criminal unit’s attention in the crypto sphere. The article discusses possible implications of the Department of Justice’s early February

Federal Bar Association 2024 Tax Law Conference (CLE/CPE)

Join the Section on Taxation for the 48th Annual Tax Law Conference. This three-day program will offer the same great content in-person and online. Programming will be held in-person on Friday, March 1 and virtually from Monday, March 4 – Tuesday, March 5. Programming will include a keynote luncheon address

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. It remains unclear whether these

Tax Controversy and the Partnership Representative in the BBA Audit Context

Megan Brackney will participate in a program titled “Tax Controversy and the Partnership Representative in the BBA Audit Context” hosted by the Practicing Law Institute. Event Description:  The Bipartisan Budget Act of 2015 (“BBA”) changed the way adjustments are made in the partnership context by enacting new partnership audit rules.

Congress Acts to End ERC Program and Targets ERC Promoters

Proposed Bill Would Bar ERC Claims After January 31 and Increase Promoter Penalties Today, House Ways and Means Committee Chairman Jason Smith (R-Mo.) and Senate Finance Committee Chairman Ron Wyden (D-Ore.) proposed a bipartisan bill that would bar the filing of Employee Retention Credit (“ERC”) claims after January 31, 2024. The proposed

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 article. Read the new ABA