Kostelanetz attorneys Caroline D. Ciraolo, Andrew Weiner, and Michael Waalkes recently asked the Fourth Circuit to reverse and remand a U.S. Tax Court ruling that denied a request for innocent spouse relief. In LaRosa v. Commissioner (No. 24-2034), Kostelanetz argues that liabilities consisting of an erroneous refund of payments of interest on
Christopher Ferguson and Michael Waalkes write in a recent CPA Journal article about the increased popularity of decentralized finance (“DeFi”) and the complicated tax issues triggered by DeFi activity. DeFi is a blockchain-based, peer-to-peer system that is used for conducting financial activity without the need for third-party intermediaries or financial
Tax-exempt organizations may be entering a new era of heightened scrutiny of their tax-exempt status. Michael Waalkes, Caroline D. Ciraolo, and Melissa Wiley co-authored a piece for Procedurally Taxing/Tax Notes discussing potential legal avenues through which an exempt organization might challenge its designation as an organization supporting terrorism and the
Caroline Ciraolo, Melissa Wiley, and Michael Waalkes will present a Kostelanetz webinar on April 24, 2025, addressing key issues that may arise in representing exempt organizations in tax examinations, administrative appeals, and litigation. The discussion will review potential grounds for denial of an application for, or suspension or revocation of
Businesses that employ individuals who are not authorized to work (unauthorized individuals) in the United States are the subject of increasing scrutiny by the Internal Revenue Service (IRS), Homeland Security Investigations (HSI), the Department of Labor (DOL), and other federal and state government agencies. Recently, the IRS and the Department
Kostelanetz attorneys Michael Waalkes, Abigail Burke, and Jay R. Nanavati will be presenting on various tax topics at the American Bar Association Tax Section’s May Meeting May 8-10, 2025. Topics Kostelanetz attorneys will cover include the U.S. Supreme Court’s decision to consider Zuch v. Commissioner, IRS guidance on the ability
Michael Waalkes and Melissa Wiley were cited in a recent Tax Notes column titled “Listed Transactions and the Trump Administration — What Happens Now?” Stephen J. Olsen, the faculty director of the Graduate Tax Program at Villanova University’s Charles Widger School of Law and a partner at Gawthrop Greenwood PC,
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
Kostelanetz attorneys will participate in a variety of panels and presentations at the American Bar Association Tax Section’s 2024 Midyear Tax Meeting in San Francisco, CA on January 18-20, 2024. Thursday, January 18, 2024 1:30 PM – 2:30 PM (PST): Andrew Weiner participates in a panel titled “Equitable Tolling and
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