By Bryan C. Skarlatos and Stephen A. Josey Journal of Tax Practice and Procedure October – November 2019 Edition Tax law is famously complex – a constantly shifting maze of statutes, regulations, IRS publications, and case law. As such, the process of filing tax returns can be an arduous task for the hundreds
By Megan L. Brackney Journal of Passthrough Entities September – October 2019 Edition As Treasury and the IRS implement the Tax Cuts and Jobs Act (“TCJA”) of 2017, it is a good time to consider when taxpayers can rely on informal IRS guidance, such as publications, forms, instructions, and frequently asked
By Caroline Rule The CPA Journal October 2019 Edition Internal Revenue Code (IRC) section 7216 and its lengthy regulations govern when a tax return preparer may disclose or use a taxpayer’s tax return information without first obtaining the taxpayer’s consent. Because it is a federal crime to violate section 7216 and
By Kevin M. Flynn The CPA Journal September 2019 Edition The itemized deduction for state and local taxes (SALT) under Internal Revenue Code (IRC) section 164 had long provided relief to taxpayers residing in high income and property tax states such as New York, New Jersey, and Connecticut. It assured these
By Caroline Rule The Journal of the Section of Litigation Vol. 45 No. 4 Summer 2019 Marriage is perplexing, and the marital privileges even more so. Contradictory views determine when they apply and what they protect. In many states, statutes, rather than case law, govern, but federal law leaves it to
By Megan L. Brackney Journal of Passthrough Entities May – June 2019 Edition Under the injunction statutes in the Internal Revenue Code, the U.S. government has broad discretion to seek—and the federal courts to order—the injunction of the preparation of false or fraudulent returns, as well as the aiding and abetting
By: Robert S. Fink LexisNexis 38th Ed. 2019 The 38th edition of “Tax Controversies: Audits, Investigations, Trials” has published and is available on Lexis-Nexis. Authored by Kostelanetz & Fink co-founder Robert S. Fink and the attorneys of Kostelanetz & Fink, Tax Controversies is the recognized guide to all stages of tax examination, investigation,
By: Megan L. Brackney The CPA Journal June 2019 Edition Although some are unaware of the fact, taxpayers can recover fees and costs from the government if the IRS has taken an unreasonable position against them. The IRS may be responsible for fees due to unreasonable positions that it took during
By: Michael Sardar The CPA Journal May 2019 Edition The Tax Cuts and Jobs Act (TCJA), signed into law on December 22, 2018, delivered sweeping changes to the federal tax code. These changes brought with them ambiguity and uncertainty, which will likely lead to federal tax audits and disputes on how
By: Bryan C. Skarlatos and Stephen A. Josey Journal of Tax Practice & Procedure February – March 2019 Edition Tax law is so complicated that nearly everyone makes a mistake sooner or later. What should a taxpayer do when he or she learns of a mistake on a previously filed tax return? Of
