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
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 CryptocurrencyWe wrote yesterday that the Internal Revenue Service has issued guidance to taxpayers and practitioners about how the agency’s resumption of activities this week following the government shutdown is impacting
Continue Reading IRS Publishes Frequently Asked Questions About Resumption of Audits Following Shutdown
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
As many readers know, the Bipartisan Budget Act of 2015 (“BBA”) repeals the long standing TEFRA procedures governing IRS examinations of partnerships. As a result, beginning January 1, 2018, partnerships
Continue Reading IRS Issues Guidance to Examiners Handling BBA Partnership Audits
I was recently interviewed by the Wall Street Journal about the IRS LB&I audit campaigns discussed here. An interesting part of the conversation included a discussion of why the
Continue Reading IRS Audit Campaigns: What this means for taxpayers