Internal Revenue Code

The IRS is sending out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. The IRS will

Continue Reading IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

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

In its most recent effort to fight fraudulent and improper Employee Retention Tax Credit (ERC) claims, on December 6, 2023, the IRS announced it will be notifying an initial group

Continue Reading IRS Rejects 20,000 Employee Retention Tax Credit Claims, Plans to Offer New Voluntary Disclosure Program

The IRS recently announced that it will offer certain employers an opportunity to withdraw Employee Retention Credit (ERC) claims if they are concerned about their accuracy. Qualifying employers may be

Continue Reading Amid Fraud Investigations, IRS Offers Employers an Opportunity to Withdraw Inaccurate Employee Retention Credit Claims

       In Notice 2023-71, the IRS provided tax relief for individuals affected by Hamas’ terroristic action in the State of Israel beginning on October 7, 2023.  Notably, this relief is not

Continue Reading IRS Provides Extensions for Taxpayers Impacted by Hamas Terrorism in Israel

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

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

Recently, the written supervisory approval requirement of Section 6751(b) has been one of the primary issues in Tax Court litigation concerning penalties that the IRS has asserted against taxpayers. The
Continue Reading Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding

United States v. Gerard, a recent case from the Northern District of Indiana, demonstrates how a tax lien, once attached, can stay with property even after the property is
Continue Reading District Court Holds Tax Liens Stay with Property after Conveyance