General Tax Controversy News & Updates

A former trial attorney for the IRS, Fox Rothschild Counsel Brian Bernhardt has a unique perspective to offer clients facing tax controversies and litigation. In a chat with Kristopher Flammang

Continue Reading Brian Bernhardt Featured on The Confident Retirement Podcast, Speaking about his Tax Controversy and Tax Litigation Practice

The Tax Court’s recent decision in Walquist v. Commissioner, 152 T.C. No. 3, further clarified the application of the supervisor approval requirement under section 6751(b)(1), which has been a
Continue Reading Tax Court Holds that Supervisor Approval Requirement Does Not Apply to Penalties Determined by Computer Program

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

The IRS has been cracking down on conservation easement transactions for over ten years. Nevertheless, taxpayers have continued to claim charitable contribution deductions attributable to the donation of conservation easements
Continue Reading Conservation Easements: A Year End Review

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

We recently wrote on the new proposed regulations addressing the availability of charitable deductions when taxpayers receive or expect to receive corresponding state or local tax credits for contributions.  The
Continue Reading IRS Provides Clarification for Business Taxpayers That Make Payments To State or Local Tax Credit Programs