Some audits are about bad math (or bad records): The
taxpayer has one set of numbers and the government grades her. Others are more
complicated: The taxpayer has carefully structured one or more transactions to
reach a particular result; the
When most people think about the Internal Revenue Code, they think about the income tax. More sophisticated individuals may also mention estate and gift taxes. But the Code is also full of excise taxes. They are imposed on diesel fuel,
Joseph and Amy McKenny sued their accountants for
malpractice based upon faulty tax advice, settling for $800,000. The
settlement, however, did not end their legal problems, as they wound up
litigating with the federal government over the tax treatment of
The Bankruptcy Code sets priorities for certain claims to help assure that they get paid. 11 U.S.C. § 507(a). A tax can qualify as an administrative expense, the second-highest priority,1 if it is
(i) incurred by the estate, whether
When lawyers communicate with clients, two privileges may be
implicated:
States and municipalities compete for the attention of businesses that seek to relocate. As a prominent example, Amazon’s decision to establish a second headquarters set off a bidding war in 2018. New York State won with a package that reportedly
The First Rule of Holes: When you’re in a hole, stop digging.
Wrentham House
is a 14,400 square-foot waterfront mansion in Newport, Rhode Island. David and
Candace Keefe purchased the property in 2000 for $1.35 million. Keefe v. Comm’r, Nos.
On July 7, 2020, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released its second advisory to financial institutions about detecting and preventing COVID-19 consumer fraud. The guidance provides financial institutions with 18 new red flag indicators to help
Taxpayers who pay more tax than is due have the right to sue
for a refund after exhausting their administrative remedies, and they may file
suit either in a district court or in the Court of Federal Claims, as the
The IRS has broad investigatory powers, which include the
power to issue a summons compelling the production of records, testimony, or
both. See I.R.C. § 7602(a)(2). If the
recipient of a summons refuses to comply, enforcement proceedings will follow
in