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tax Advice Archive

Recent Developments in Partnership Audits (Part 2)

TweetShareSharePin0 Shares In yesterday’s post Rochelle Hodes, Principal with Crowe LLP, provided background on BBA, emphasizing what makes its rules unique in tax procedure. Today’s post will briefly discuss two important BBA developments, the IRS’s Large Partnership Compliance Program and significant ABA Tax Section comments on proposed BBA regulations. Les The IRS is scheduled to

FAWBU and Dispute Resolution Redux – Part 2

TweetShareSharePin0 Shares In Part 1 of this posting series, I proposed a 12-step program for getting the IRS to finally embrace its dual mission of collecting revenue and administering various social benefit programs.  There is one more step that must be addressed for the IRS to effect cultural change:  the development of a dispute resolution

So You Want to Raise an IRC § 7602(e) Issue…

TweetShareSharePin0 Shares Previously, I wrote about why it is IRC § 7602(e) wouldn’t keep the IRS from using information returns from banks to audit taxpayers. Let’s now suppose my analysis from the prior post is completely and entirely wrong and the IRS can’t use information returns in the way I suggest. What happens if the

Taxpayer Fails in Effort to Dismiss Erroneous Refund Suit

TweetShareSharePin0 Shares In United States v. Sharpe, No. 2:20-cv-02490 (E.D. Pa. 2021) the court denied the taxpayer’s motion to dismiss an erroneous refund suit filed against her by the IRS.  The denial of the motion still leaves her with the opportunity to argue against the imposition of the erroneous refund provision on its merits.  It

Guidance issued for LLCs seeking tax-exempt recognition

TweetShareSharePin0 Shares The IRS on Thursday issued Notice 2021-56 to clarify the standards that a limited liability company (LLC) must satisfy to receive a determination letter recognizing it as tax-exempt under Sec. 501(c)(3). Generally, all the members of an LLC seeking tax-exempt status will have to be tax-exempt organizations themselves or governmental units. The LLC

IRS Releases Update on Frequently Asked Questions Part 4: The Low-Income Taxpayer Perspective

TweetShareSharePin0 Shares The IRS’s mission, in its own words, is to “Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities and enforce the law with integrity and fairness to all.”  Taxpayers reading this mission statement are not being unreasonable in believing that fulfilling the service side of this mission

IRS Recent Guidance on FAQs: Too Little, Too Narrow

TweetShareSharePin0 Shares Today we welcome back guest bloggers Alice Abreu and Richard Greenstein, Professors of Law at Temple’s Beasley School of Law in Philadelphia, with the third installment in our mini-series on IRS FAQ. On Friday, October 15, 2021, the IRS finally issued guidance addressing the controversial issue of taxpayer reliance on positions the agency announces
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