The Internal Revenue Code requires employers to withhold certain taxes in “a special fund in trust for the United States” (sec. 7501(a)). IRS regulations require employers to pay these trust
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Pennsylvania Supreme Court: Corporate Tax Refund Claim Must Be Filed Within Three Years Of Original Tax Return Due Date
In Mission Funding Alpha, the Pennsylvania Supreme Court recently held that the statute of limitations for a corporation to file a refund claim in Pennsylvania begins to run when
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Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized
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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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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