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IRS Targets Private Foundations That May Be Used by Wealthy Taxpayers in Tax Planning

USA - June 26 2020 ​In remarks at the NYU Tax Controversy Forum on June 18, 2020, Internal Revenue Service (IRS) officials indicated that the agency is analyzing the…

Andrew R. Roberson, Kevin Spencer.

IRS Releases Fact Sheet on Acceptable Electronic Signatures

USA - September 9 2021 The Internal Revenue Service (IRS) released a Fact Sheet, providing guidance on acceptable methods for taxpayers to electronically or digitally sign…

Andrew R. Roberson, Kevin Spencer.

Senate Democrats Propose Overhaul of Clean Energy Incentives

USA - April 23 2021 US Senate Finance Committee Chairman Ron Wyden (D-OR) introduced the Clean Energy for America Act (the Act), along with two dozen Democratic…

Heather Cooper, Carl J. Fleming, Elle Hayes, Martha Groves Pugh, Philip Tingle.

Tax Court Holds IRS Chief Counsel Attorneys May Make Initial Penalty Determination

USA - June 8 2020 In general, section 6751 requires that a supervisor give written approval before penalties can be asserted against a taxpayer. In Koh v. Commissioner…

Andrew R. Roberson, Kevin Spencer.

Tax Court Holds That Form 870-AD Is Not a Binding Settlement Agreement

USA - June 10 2020 A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude…

Andrew R. Roberson, Kevin Spencer.