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Tax Controversy Blog Blog

Articles: 11-20 of 22

Update on Hurricanes Irma, Harvey, and Maria Disaster Relief: The IRS has a Change of Heart Regarding the Filing Deadlines for IRS Form 8886.

USA - October 2 2017 On September 28, 2017, we released a blog regarding the disaster relief provided by the IRS in the wake of Hurricanes Harvey, Irma, and Maria, which…

Listed Transaction Update: Hurricane Disaster Relief Does NOT Extend the October 2, 2017 Deadline to File IRS Form 8886.

USA - September 28 2017 Due to the catastrophic damage caused by Hurricanes Harvey, Irma, and Maria, the IRS is providing relief to taxpayers affected by the storms in the…

Tax Court Slams IRS Penalty Argument: Penalties Abated Due to Reliance on CPA

USA - August 15 2017 Last month, the Tax Court handed a large victory to a taxpayer who failed to report certain U.S. income. The Tax Court held that the taxpayer was not…

Real Estate Professionals - Substantiation and Logic Reign Supreme in Demonstrating Real Estate Professional Status

USA - May 8 2017 The Tax Court recently entered two decisions concerning material participation by taxpayers claiming real estate professional status that reached…

Limited tax amnesty coming to Alabama in 2016

USA - October 1 2015 A limited tax amnesty program was enacted recently in Alabama. The program seems useful mainly for taxpayers who have been “off the radar” in recent…

Tax breaks that Congress loves but the IRS hates mean big audit headaches for taxpayers

USA - September 10 2015 The IRS has now taken it upon itself to vigorously pursue taxpayers taking advantage of certain tax breaks that the IRS does not like, even though…

Conspiracy indictment relating to undisclosed foreign account not time-barred due to subsequent filing omissions

USA - July 8 2015 In U.S. v. Canale, DC NY, 115 AFTR 2d ¶2015-851, the United States District Court for the Southern District of New York decided that an indictment…

First Circuit tells late filers that tax debts are not dischargeable in bankruptcy

USA - June 2 2015 The First Circuit recently joined the Tenth and Fifth Circuits in determining that untimely tax returns are not "returns" for purposes of discharging…

IRS audit process expected to move even slower – plan accordingly

USA - January 16 2015 As reported in the BNA Daily Tax Report on January 14, 2015, IRS Commissioner John Koskinen said in an e-mail to employees and stakeholders on…

Coming clean with foreign accounts: the best and easiest New Year’s resolution to make (and keep)

USA - December 11 2014 It’s that time of the year when resolutions will soon be made and subsequently broken. According to the University of Scranton Journal of Clinical…