When you do not pay your taxes, the Internal Revenue Service (IRS) has the power to file a “lien” on your property under Internal Revenue Code section 6321. The lien attaches “upon all property and rights to property, whether real
Tax Controversy 360
McDermott’s Real-Time Tax Disputes Insights
Tax Controversy 360, published by McDermott Will & Emery, focuses on issues related to tax disputes and controversies involving the Internal Revenue Service and other tax authorities. The blog covers topics such as IRS enforcement actions, audit strategies, tax planning risks for high-net-worth individuals, regulatory updates, and procedural developments in tax litigation. It also addresses the impact of legislative changes and administrative guidance on tax controversy practice, including insights on private foundations, tax court procedures, and tax implications of current events like the COVID-19 pandemic. The content is aimed at tax professionals, advisors, and taxpayers navigating complex tax dispute environments.
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Weekly IRS Roundup April 15 – 19, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 15 – 19, 2019.
April 16, 2019: The IRS issued Revenue Ruling 2019-12 providing monthly tables of prescribed rates…
Ninth Circuit Allows IRS to Overrule Common-Law Mailbox Rule
Most tax professionals are aware of the common-law “mailbox rule,” which provides that proof of proper mailing creates a rebuttable presumption that the document was physically delivered to the addressee. Internal Revenue Code (Code) section 7502 was enacted to codify…
IRS Announces More LB&I Campaigns!
Second Circuit Weighs in on Tax Court’s Refund Jurisdiction
Borenstein v. Commissioner is an interesting opinion involving the intersection of canons of statutory construction and jurisdiction. Recently, the US Court of Appeals for the Second Circuit reversed the US Tax Court’s holding in Borenstein that the court lacked jurisdiction…
Weekly IRS Roundup April 8 – 12, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 8 – 12, 2019.
April 8, 2019: The IRS issued a news release warning taxpayers against rushing to file…
Tax Court Rules State Corporate Incentives Are NOT Taxable Income Under Federal Law
By Le Chen & Kevin Spencer
Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these incentives are taxable income under federal income tax law. Internal Revenue Code (IRC) section 118, as…
Weekly IRS Roundup April 1 – 5, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 1 – 5, 2019.
April 2, 2019: The IRS issued a news release providing tips on payment options, penalty…
Weekly IRS Roundup March 25 – 29, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 25 – 29, 2019.
March 25, 2019: The IRS issued Proposed Regulations under Section 301 of the code updating…
Weekly IRS Roundup March 18 – 22, 2019
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 18 – 22, 2019.
March 18, 2019: The IRS cancelled a public hearing originally scheduled for March 20th on…