We have all heard the old proverb “if it’s too good to be true, then it probably is.” In the tax world, this proverb might as well be referred to
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Civil Tax
Tax Court Allows Petitioner to Claim Unsubstantiated Deductions
The issue before the Tax Court in Huzella v. Commissioner, T.C. Memo. 2017-210, centered around a coin business on eBay, and whether the petitioner, Thomas Huzella, could substantiate his…
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IRS Audits of Cannabis Companies and the Importance of Substantiation
Today, the Tax Court issued its opinion in Feinberg v. Commissioner, a case involving an ongoing and hard fought battle between the IRS and a medical marijuana dispensary, Total…
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TIGTA Determines Improvements are Needed in Estate and Gift Examination Processes
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…
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Tax Relief for Victims of Hurricane Harvey
The President has declared a major disaster in the State of Texas. The declaration permits the IRS to postpone certain deadlines for taxpayers who reside or have a business in…
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Courts Issue Victories to Conservation Easement Donors
August brought three wins for taxpayers who donated conservation easements that were challenged by the IRS. In all of the cases, terms of the conservation easement deed document carried the …
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Tax Court Issues Opinion Striking Down Captive Insurance Arrangement
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…
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With Tax Day Nearly Behind Us, Justice Department Pivots to Warnings About Employment Tax Violations
Following a relentless flurry of press releases announcing criminal charges against tax evaders in the run up to today’s tax filing deadline (see here, here, and here),…
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Colorado District Court: IRS Enforcement of Section 280E Is Not A Criminal Investigation
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…
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IRS Provides Sample Letter Informing Taxpayers that Their Account was Referred to a Private Collection Agency
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…
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