IRS Audits

The IRS has announced a new Voluntary Disclosure Program (VDP) offering businesses a limited-time opportunity to repay improperly claimed Employee Retention Credits at a discount while avoiding penalties and interest. The VDP requires businesses to repay only 80% of the improper credits they received and has an application deadline of March 22, 2024.
Continue Reading New IRS Voluntary Disclosure Program Lets Businesses Repay Questionable Employee Retention Credits at a Discount

       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

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

By Adam R. Young and Brian Bernhardt

On January 13, 2023, the IRS issued Chief Counsel Memorandum 202302012 (the “CCM”) establishing new rules for donations of cryptocurrency.  In the CCM

Continue Reading IRS Cracks Down on Charitable Contributions of Cryptocurrency

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

Yesterday the Internal Revenue Service’s Large Business and International Division announced that it was adding six more compliance campaigns to its previously-announced list of 29 such campaigns. The compliance campaigns
Continue Reading Internal Revenue Service’s LB&I Division Announces Six More Compliance Campaigns

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
Continue Reading TIGTA Determines Improvements are Needed in Estate and Gift Examination Processes