Equitable Tolling Opens the Tax Court Door: The Impact of Oquendo v. Commissioner... [ read ]
Joel N. Crouch examines the Sixth Circuit's recent decision in Oquendo v. Commissioner and its impact on the long-standing 90-day Tax Court petition deadline.
Employee Retention Credit (ERC) Examinations Surge... [ read ]
Jeffrey M. Glassman examines the IRS's intensified examinations surrounding Employee Retention Credit claims and how businesses can best prepare for heightened scrutiny.
How a BBA Partnership Representative Can Ruin Your IRS Audit... [ read ]
Nick S. Pegelow explores the risks partnerships face under the Bipartisan Budget Act (BBA)'s Centralized Partnership Audit Regime, and highlights the role of Partnership Representatives.
Silver Moss Properties, LLC v. Commissioner: A Tax Court Showdown Over Conservation Easements and the Right to Jury Trial... [ read ]
Joel N. Crouch delves into the Tax Court's recent decision in Silver Moss Properties LLC v. Commissioner and the key areas of focus of the IRS's continued scrutiny.
Is the Issue of Fraudulent Conduct by the Return Preparer and the Tax Assessment Statute of Limitations Headed to the U.S. Supreme Court?... [ read ]
Joel N. Crouch analyzes whether the U.S. Supreme Court may soon weigh in on a critical tax controversy: does the indefinite statute of limitations for tax assessments apply when fraud is committed by a return preparer without the taxpayer's knowledge?
How an IRS PLR Can Help with a Missed IRA Rollover Due to Fraud... [ read ]
Matthew L. Roberts examines how an IRS Private Letter Ruling can provide critical relief for taxpayers who miss the IRA rollover deadline due to fraud.
A Step in the Right Direction: Appeals Case Memos can now be Shared with Taxpayers... [ read ]
Firm partner Jeffrey M. Glassman explores a major win for transparency in tax disputes: the IRS Independent Office of Appeals will now share Appeals Case Memoranda (ACMs) with taxpayers upon informal request.
OBBBA Revises Existing GILTI Tax Rules Applicable to CFCs... [ read ]
Matthew L. Roberts analyzes how the One Big Beautiful Bill Act (OBBBA) rewrites key provisions of the GILTI regime for US shareholders of controlled foreign corporations.
State Disasters Now Qualify for Federal Tax Relief... [ read ]
Nick S. Pegelow unpacks the important expansion of the IRS's disaster relief powers that could provide a lifeline to taxpayers impacted by state-declare emergencies.
IRS Focus Turns to Form 3520-A and Foreign Grantor Trusts... [ read ]
Firm partner Matthew L. Roberts examines the IRS's intensifying scrutiny of Form 3520-A and foreign grantor trusts and the increased audit risks that come along with these changes.
