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 IntelligenceIn 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
The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy act applies on a “per-form” basis, not a “per-account” basis, handing individuals an important victory.
Continue Reading U.S. Supreme Court Rules Against Government in FBAR Penalty Case
Following up our post earlier today that the Tax Court will resume receiving mail on July 10, 2020, the Tax Court has issued another announcement regarding its operations. Also beginning
Continue Reading U.S. Tax Court to Begin Accepting Hand Deliveries on July 10
Due to the COVID-19 pandemic, operations of the United States Tax Court have been severely impacted. The Tax Court’s building in Washington, D.C. has been closed since March 19, 2020,
Continue Reading Tax Court Announces Resumption of Mail Delivery
The United States Tax Court issued a press release today announcing that more trial sessions have been cancelled in light of the COVID-19 pandemic. All trial sessions through the end
Continue Reading Tax Court Cancels All Trial Sessions Through June 2020
The United States Tax Court announced today that in light of the growing threat posed by the coronavirus, it was cancelling the following upcoming trial sessions:
March 16, 2020: Hartford
Continue Reading Tax Court Cancels March 2020 Trial Sessions Due to Coronavirus
The United States Tax Court announced earlier this week that Chief Judge Maurice B. Foley has been re-elected and will serve another two-year term beginning June 1, 2020. His current
Continue Reading Chief Judge Foley Re-Elected Chief Judge of the United States Tax Court
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