Yesterday the Tax Court issued its much awaited opinion in Patel v. Commissioner. After the Court disallowed deductions attributable to Patel’s captive insurance arrangement, it ordered briefing on the
Continue Reading Tax Court Economic Substance Ruling is a Mixed Bag for TaxpayersIRS Criminal Investigation Unit to Target Tax-Exempt Entities and Political Donors
By Adam Young on
On October 15, 2025, the Wall Street Journal (WSJ) reported that the Trump administration plans to install administration-friendly officials in the IRS Criminal Investigative Division (IRS CI) to investigate left-leaning…
Continue Reading IRS Criminal Investigation Unit to Target Tax-Exempt Entities and Political DonorsThe Government Shutdown Could Lead to Collections Nightmares for Taxpayers
By Meeren Amin on
As everyone (hopefully) knows, the Government has been shut down for over two weeks now. Much has been written about the IRS having to furlough nearly half of its workforce…
Continue Reading The Government Shutdown Could Lead to Collections Nightmares for TaxpayersIRS Makes Top Leadership Moves While Federal Government Remains Shuttered
By Matthew D. Lee on
As the federal government shutdown passes the two-week mark, and as thousands of Internal Revenue Service employees face furloughs and/or firings, the tax agency has announced a series of significant…
Continue Reading IRS Makes Top Leadership Moves While Federal Government Remains ShutteredIRS Has Funds to Continue Operations for Five Business Days After Potential Midnight Government Shutdown
By Brian Bernhardt on
Despite the apparent forthcoming government shutdown at midnight tonight, the IRS is prepared to briefly continue its operations according to its “lapsed appropriations” plan. The plan, released yesterday, September 29…
Continue Reading IRS Has Funds to Continue Operations for Five Business Days After Potential Midnight Government ShutdownIRS Provides Second Extension for Taxpayers Affected by Terrorist Attacks in Israel
By Brian Bernhardt on
In Notice 2025-53, the IRS provided relief for individuals and businesses affected by terrorism in the State of Israel throughout 2024 and 2025. The new notice extends the relief granted…
Continue Reading IRS Provides Second Extension for Taxpayers Affected by Terrorist Attacks in IsraelTexas Court Arms Taxpayers with a Powerful New Defense to FBAR Penalty Lawsuits
By Matthew D. Lee on
A district court in Texas has dismissed a lawsuit filed by the Justice Department to collect an FBAR penalty, concluding for the first time that the Internal Revenue Service’s administrative…
Continue Reading Texas Court Arms Taxpayers with a Powerful New Defense to FBAR Penalty LawsuitsDOJ Tax Division Leader Departs Amid Large-Scale Reorganization
By Matthew D. Lee on
The head of the Justice Department’s Tax Division has departed for private practice, just as the planned dismantling of the Tax Division was set to take place. Karen Kelly, who…
Continue Reading DOJ Tax Division Leader Departs Amid Large-Scale ReorganizationIRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two Months
By Matthew D. Lee on
On August 8, President Donald Trump abruptly removed Billy Long from his position as Commissioner of Internal Revenue, making Long’s tenure the shortest for a Senate-confirmed commissioner in the tax…
Continue Reading IRS Leadership Turmoil Intensifies as Commissioner Billy Long Is Removed After Just Two MonthsFox Rothschild’s Fourth Annual White Collar Symposium
By Matthew D. Lee on
Please join us for our annual White Collar Symposium where our attorneys and guest speakers will unpack the most pressing issues in white-collar criminal defense, government investigations and regulatory compliance.…
Continue Reading Fox Rothschild’s Fourth Annual White Collar Symposium