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Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.

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Dallas, TX 75202

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June 30, 2025

Yum! Brands Challenges IRS on "Killer B" Regualtions... [ read ]

In our latest blog post, Nick S. Pegelow examines Yum! Brands' high-stakes case regarding "Killer B" anti-abuse regulations, international reorganizations and when a "B Reorg" triggers a US tax bill.

June 25, 2025

Taxpayer Advocate Convinces IRS to Remove Willfulness Requirement for Voluntary Disclosure Program... [ read ]

The Taxpayer Advocate convinced the IRS to ‘undo' a recent, highly criticized change to the Voluntary Disclosure Program that required the taxpayer's admission of willfulness prior to participation.

June 23, 2025

Proof That Dotting the I's and Crossing the T's Keeps the IRS at Bay... [ read ]

In our latest blog post, Joel Crouch discusses the case Estate of Barbara Galli v. Commissioner, and how every detail counts in tax-sensitive transactions.

June 20, 2025

Strategic Considerations for Tax-Exempt Status Revocation IRS Examinations... [ read ]

In our latest blog post, Jeffrey M. Glassman explores the high-stakes of IRS examinations that can lead to an organization's tax-exempt status being revokes.

June 9, 2025

Court Finds in Favor of Taxpayer on TurboTax Form 3520 Penalty Defense... [ read ]

In our latest blog post, Matthew Roberts analyzes Huang v. United States, a recent case in which a taxpayer challenged IRS Form 3520 penalties.

June 4, 2025

Foreign Grantor Trusts & U.S. Taxes: Understanding Section 679... [ read ]

In our latest blog post, Matthew Roberts explores the complex tax implications of foreign grantor trusts under Section 679 with U.S. beneficiaries.

May 28, 2025

Refund Litigation Continued: Types of Cases... [ read ]

This blog builds on prior posts concerning refund litigation. This blog explores the types of tax refund cases that can be brought in the U.S. district courts and the U.S. Court of Federal Claims.

May 27, 2025

Tax Residency: Key Differences Between the U.S. Income and Transfer Tax Rules... [ read ]

The application of U.S. tax laws often turns on the meaning of "residency." Although U.S. citizens and residents are subject to federal income taxes on their worldwide income, non-residents who are not U.S. citizens ("Foreign Persons") are generally not unless the income has a nexus to the U.S. Under the U.S. income tax regime, individuals may establish residency through their physical presence in the U.S.

May 23, 2025

A Sample of Tax Cases in Federal District Court: Criminal vs. Civil... [ read ]

Most federal tax disputes are resolved administratively or in the United States Tax Court, where taxpayers might challenge IRS determinations in a specialized forum that requires no prepayment of the disputed tax. But not all tax cases follow that path.

May 14, 2025

Late-Filing Penalties, Reasonable Cause, & Boyle... [ read ]

There are more than 100 penalties in the Internal Revenue Code. Each penalty varies in scope, but a common defense for almost all of them is "reasonable cause." Where this defense applies, the IRS can't impose penalties.

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