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
Tax Controversy Posts, published by Post & Schell, P.C., focuses on legal issues related to tax disputes and enforcement under the Internal Revenue Code. The blog covers topics such as penalties associated with the Affordable Care Act, IRS examinations, employer shared responsibility payments, and anti-money laundering priorities. It addresses procedural aspects of tax controversies, including IRS audits, notices of deficiency, and taxpayer rights during collection processes. The content also explores regulatory developments and compliance challenges faced by individuals and businesses in tax-related matters.
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…
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…