Archive for the ‘Uncategorized’ Category
The IRS Has Become More Aggressive in Assessing Form 3520 and Form 3520-A Foreign Information Reporting Penalties, but the Courts Don’t Always Approve By: Michel Stein and Robert S. Horwitz
Posted by: Robert Horwitz on December 2, 2019
Federal Circuit Upholds Liability for FBAR Willful Penalty, Determines the Regulation Limiting Penalty to $100,000 Is Invalid by Robert S. Horwitz
Posted by: Robert Horwitz on November 11, 2019
4th Circuit Upends Longstanding DOJ Practice for Filter Teams to Review Attorney-Client Privileged Materials By Evan J. Davis
Posted by: evanjdavis on November 6, 2019
Tax Court Update: Majority Holds Section 280E Is Constitutional, But Three Judges Join In Persuasive Dissent by Jonathan Kalinski
Posted by: jkalinski on October 31, 2019
AOD 2019-03: Non-Acquiescence to Tax Court Ruling Regarding the Tax Treatment of a Franchise Transfer – by Sandra Brown[1] and Gary Markarian[2]
Posted by: sbbrown64 on October 20, 2019
The New California Office of Tax Appeals Demonstrates Its Independence from the FTB by Robert S. Horwitz
Posted by: Robert Horwitz on October 14, 2019
Will There Be Greater IRS Scrutiny of Corporate Merger & Acquisition Transactions By Steven Toscher and Tenzing Tunden
Posted by: Steven Toscher on October 1, 2019
Your Small Business IRS Examination Might Take a Criminal Turn by Jonathan Kalinski
Posted by: Robert Horwitz on September 27, 2019
Court Confirms the IRS Can’t Get Blood from a Stone by Evan J. Davis
Posted by: evanjdavis on September 25, 2019
