The IRS, like the rest of society, has faced several challenges as a result of the pandemic. Some of those challenges are still lingering, such as funding, backlog, lack of guidance and inexperienced auditors. Efforts to fix these problems are
Latest from Texas Tax Talk
Tony Box Quoted by Law360 on Trump Lieutenant’s Plea
Former Trump Organization Finance Chief Allen Weisselberg pled guilty last week to 15 felonies for what he admitted was a tax fraud scheme he committed while an executive for Trump’s company. Law360 covered the story and quoted Gray Reed Partner
Politically-Motivated Criminal Cases Based on Perjured Testimony Really DO Happen! Even if You Work for the IRS
Today’s news media is full of stories about supposed malicious allegations, unfounded criminal investigations and indictments based on perjury.
Regardless of our political leanings, all of us should hope that such things are actually exceedingly rare. However, a case decided
IRS Continues to Hunt for Cryptocurrency Investors with John Doe Summonses
UPDATE: On August 15, 2022, Judge Otis D. Write II in the Central District of California entered an order approving service of the summons by the IRS on sFOX for account and transaction records. The Department of Justice entered a
A Close Look at the Decentralized Effort to Tax Digital Assets
Cryptocurrency is no longer a new asset — it’s been around since 2009 — and the number of individuals and businesses who own or use cryptocurrency and NFTs, and the underlying blockchain technology, continues to increase with each passing year.
IRS Penalty Denied Because of Poor Penmanship
Many people, myself included, can sometimes be accused of poor penmanship. As our paperwork becomes more and more electronic, we write less and less down with pen and paper. However, a recent decision from the tax court may be sending more
Protecting Client Information When Using Accountants in Legal Matters
It is well-established that attorneys and their clients are entitled to private and protected communications. But what level of protections are available when an accountant is used in an engagement to provide an area of expertise not possessed by the
Supreme Court Will Hear Non-Willful FBAR Penalty Dispute
On June 21, 2022, the United States Supreme Court agreed to hear a dispute involving split decisions among the circuit courts on non-willful penalties. The Fifth Circuit parted ways with the taxpayer friendly decision of the Ninth Circuit that non-willful
Fifth Circuit Says No Do-Overs in Oil and Gas Tax Dispute
In some federal tax disputes, if at first you don’t succeed you may not get to try again. A recent Fifth Circuit decision confirms issue preclusion when the parties and the issue are truly the same. See ETC Sunoco Holdings
Thoughts on Cryptocurrency and Tax Partnerships
Cryptocurrency holders often want to put their assets into an entity for a host of reasons, such as asset protection, arranging negotiated management rights and exit planning. This post discusses basic federal income tax issues related to holding cryptocurrency inside