Civil Tax

In its most recent effort to fight fraudulent and improper Employee Retention Tax Credit (ERC) claims, on December 6, 2023, the IRS announced it will be notifying an initial group

Continue Reading IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program

The IRS recently announced that it will offer certain employers an opportunity to withdraw Employee Retention Credit (ERC) claims if they are concerned about their accuracy. Qualifying employers may be

Continue Reading Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims

       In Notice 2023-71, the IRS provided tax relief for individuals affected by Hamas’ terroristic action in the State of Israel beginning on October 7, 2023.  Notably, this relief is not

Continue Reading IRS Provides Extensions for Taxpayers Impacted by Hamas Terrorism in Israel

The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news

Continue Reading IRS Going All in on Use of ArtificiaI Intelligence

In a monumental opinion, the Tax Court recently held that the IRS lacks authority to assess penalties imposed by IRC § 6038(b)(1) or (2). In Fahry v. Commissioner, the

Continue Reading Tax Court Rules IRS Cannot Assess Certain International Reporting Penalties

As part of the Inflation Reduction Act, the IRS will receive a nearly $80 billion funding increase, including more than $45 billion for enforcement, over the next decade. Audit staff

Continue Reading Increase in IRS Funding Leading to More Audits of Public Charities

I have written before about the battles being fought by cannabis businesses facing IRS examinations.  IRS audits raise many issues for state legal cannabis businesses operating in violation of the
Continue Reading Tenth Circuit: No Fifth Amendment Defense to the Application of Section 280E

Yesterday the Tax Court issued two decisions discussing the impact of Section 280E on cannabis businesses.  One of these cases addresses the application of Section 280E to licensed and non-licensed
Continue Reading Tax Court: Section 280E Can Apply to Non-Licensed Taxpayers Engaged in Cannabis Businesses

In the latest Tax Court opinion addressing the application of Section 280E to cannabis businesses there is no good news.  However, there is some new guidance.  In Patients Mutual Assistance
Continue Reading Section 280E Litigation Update: Harsh Results for Resellers