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
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Increase in IRS Funding Leading to More Audits of Public Charities
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
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IRS Cracks Down on Charitable Contributions of Cryptocurrency
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 CryptocurrencyIRS Publishes Frequently Asked Questions About Resumption of Audits Following Shutdown
We 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
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Section 280E Litigation Update: Harsh Results for Resellers
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
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Internal Revenue Service’s LB&I Division Announces Six More Compliance Campaigns
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
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TIGTA Determines Improvements are Needed in Estate and Gift Examination Processes
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
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IRS Issues Guidance to Examiners Handling BBA Partnership Audits
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
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IRS Audit Campaigns: What this means for taxpayers
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
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IRS Announces 13 Issues Targeted Under its New Audit Campaigns
On January 31, 2017, the IRS announced the initial rollout of its new audit strategy and identified 13 specific issues (campaigns) it will be targeting. The IRS is moving toward
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