Civil Tax

TIGTA recently released a report discusses their audit of the IRS’s estate and gift tax examination procedures.  TIGTA made eight recommendations of changes to the estate and gift tax examination
Continue Reading TIGTA Determines Improvements are Needed in Estate and Gift Examination Processes

The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from
Continue Reading Tax Court Issues Opinion Striking Down Captive Insurance Arrangement

Recently, a Colorado business protested the IRS’ disallowance of their business expenses.  The IRS alleges that the taxpayer was a Colorado medical marijuana dispensary to which Section 280E applies, as
Continue Reading Colorado District Court: IRS Enforcement of Section 280E Is Not A Criminal Investigation

Previously, we discussed Congress’s enactment of the FAST Act requiring the IRS to use private debt collection agencies to recover inactive tax receivables. In September, the IRS announced that it
Continue Reading IRS Provides Sample Letter Informing Taxpayers that Their Account was Referred to a Private Collection Agency

In a strongly worded opinion that is very favorable for taxpayers who engage in sophisticated tax planning, the Sixth Circuit overturned a Tax Court opinion denying the benefits of a
Continue Reading Sixth Circuit Acknowledges Some Tax Laws Sanction Tax Avoidance