The Texas Supreme Court Denies Government Exemption to Independent Contractor but Finds "Oddity" in Texas Comptroller Rule... [ read ]
In a recently issued decision, the Texas Supreme Court provided a holding on two important matters applicable to exemptions from tax. See GEO Grp., Inc. v. Hegar, No. 23-0149, 2025 WL 852414 (Tex. Mar. 14, 2025).
IRS Confirms Some Internet Theft Losses Are Permitted Post-TCJA But Risks Remain... [ read ]
Fraud and theft continue to rise in the United States. According to a recent FTC report, Americans lost more than $12.5 billion from fraud in 2024 (an increase of 25% from the prior year). The FBI confirmed the upward trend in early 2024, noting "an alarming increase[ ] in both the frequency and financial impact of online fraud perpetrated by cybercriminals."
Who is Subject to the Texas Sales and Use Tax Contractor Rules and Why Does it Matter?... [ read ]
Taxpayers are often surprised to learn they may be subject to the "contractor" rules for Texas sale and use tax purposes and sometimes learn of this only after hearing from a Texas Comptroller auditor. Before one can consider the implications of the "contractor" rules in Texas, which can be technical and complex, one must necessarily understand who is subject to those rules.
IRS Chief Counsel Finds Foot Fault on BBA Statute of Limitations... [ read ]
In tax controversy and litigation matters, sometimes procedure trumps the merits of a case. The statute of limitations is a great example. Even if the taxpayer made a mistake on a prior year return, the IRS generally can't open an audit if the applicable statute of limitations period has expired. The Bipartisan Budget Act of 2015 (BBA) has its own statute of limitations rules associated with partnerships.
Texas Contractors Beware of the Unforeseen Texas Sales and Use Tax... [ read ]
We often find ourselves advising clients that Texas tax auditors and investigators are not their friends. Taxpayers can sometimes be lured into a false sense of confidence with a "friendly" auditor – that is, until they receive a large tax assessment. Tax auditors are hired for one reason and one reason only, and that is to find money. As such, they are not disinterested parties when it comes to auditing or investigating taxpayers.
Tax Court Reminds Taxpayers About Documents Needed to Establish a Charitable Contribution Deduction... [ read ]
In a recent collection due process (CDP) case, Cade v. Commissioner, T.C. Memo 2025-20, the Tax Court reminded taxpayers what is required to establish a charitable contribution deduction. In Cade, the taxpayers filed their 2019 Form 1040 showing a balance due of $89,013, which they did not pay. In response to IRS collection action, the taxpayers filed a CDP request. During the CDP hearing, the taxpayers contended they had filed an amended 2019 Form 1040 which included a charitable contribution deduction of $284,553 that they overlooked on their original 2019 Form 1040. The taxpayers said that if the additional charitable deduction was allowed, the tax liability would be eliminated and they would be entitled to a refund for the 2019 tax year.
The S Corp with an Evergreen PLR... [ read ]
A Private Letter Ruling is as close as you can get to certainty in the tax world. That's why the IRS charges up to $43,700 just to look at one. But so long as you don't misrepresent the facts, a PLR is a binding interpretation of current law on both the IRS and the courts. A favorable ruling can reduce tax-return disclosures and FIN 48 adjustments included in applicable financial statements, among other benefits.
AARs: Streamlined Corrections for BBA Partnership Returns... [ read ]
Amending tax returns is a necessary evil—sometimes. Correcting a return to add $15,000 of unreported income might not make sense to taxpayers if it costs $25,000 to amend, putting aside ethical and other considerations. But suppose it's an issue with an improper method of accounting.
Meadows Collier Partners Submit Comments on Proposed Revisions to Circular 230... [ read ]
Firm partners Jeffrey M. Glassman and Matthew L. Roberts, through their respective leadership positions with the State Bar of Texas Tax Section (Tax Section), recently submitted comments to the Treasury and IRS on proposed revisions to Circular 230. Mr. Glassman serves as the Chair of the Tax Controversy Committee for the Tax Section, and Mr. Roberts serves as the committee's Vice Chair.
Court Grants Taxpayers' Motion for Summary Judgment on Proposed Civil Fraud Penalty... [ read ]
If a taxpayer cannot resolve a dispute with either IRS examination or with the IRS Office of Appeals regarding tax and penalties, the IRS will send the taxpayer a Notice of Deficiency (NOD), sometimes referred to as a 90 Day Letter. A taxpayer has 90 days to dispute the NOD by filing a petition in the United States Tax Court. If a taxpayer does not file a timely petition with the Tax Court, the IRS will assess tax and penalties in the NOD plus applicable interest. If the taxpayer still wants to dispute the assessment, he must pay the liability, file a claim for refund and if the IRS denies the refund claim, file a refund suit in either U.S. District Court or the Court of Federal Claims.
