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Tag: Civil Tax Controversies & Trials

MARITAL PRIVILEGES

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

TAX CONTROVERSY CORNER: THE INTERNAL REVENUE CODE INJUNCTION STATUTES

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

TAX CONTROVERSIES: AUDITS, INVESTIGATIONS, TRIALS

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,

Recovering Fees From The IRS

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

The IRS’s Updated Voluntary Disclosure Procedures For Offshore Accounts And Assets

By: Usman Mohammad The CPA Journal January 2019 Edition On November 20, 2018, the IRS published an Interim Guidance Memo concerning voluntary disclosures, captioned “Updated Voluntary Disclosure Practice” (https://bit.ly/2UHHdLm). The memo sets forth the IRS’s current policy for handling voluntary disclosures (both offshore and domestic) following the closing of the IRS’s

Tax Controversy Corner: Challenging Penalties Under The BBA

By Megan L. Brackney Journal of Passthrough Entities January – February 2019 Edition The Bipartisan Budget Act of 2015 (the “BBA”) made substantial changes to the audit procedures for passthrough entities. This column discusses how partnerships and individual partners will be able to challenge penalties under the BBA procedures. The BBA