Tax Controversy Litigation

There are several new developments in the Internal Revenue Service’s ongoing campaign to combat false and fraudulent Employee Retention Credit (ERC) claims.

They include an indefinite extension of the agency’s

Continue Reading IRS and Congress Expand Efforts to Address ERC Fraud

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 Intelligence

In 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