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
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
On Friday, November 3, 2017, the IRS Large Business and International division (LB&I) announced the identification and selection of 11 additional compliance campaigns. In January 2017, LB&I unveiled its first
Continue Reading IRS Large Business & International Division Rolls Out 11 Additional Compliance Campaigns for Audits
Today, the Tax Court issued its opinion in Feinberg v. Commissioner, a case involving an ongoing and hard fought battle between the IRS and a medical marijuana dispensary, Total
Continue Reading IRS Audits of Cannabis Companies and the Importance of Substantiation
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
On September 11, 2017, the Treasury Inspector General for Tax Administration (TIGTA) issued its final report discussing IRS compliance activities through fiscal year 2016 (the federal government’s fiscal year begins
Continue Reading Trends in IRS Compliance Activities Through Fiscal Year 2016
The Tax Court has issued its long-awaited decision addressing captive insurance arrangements. In Avrahami v. Commissioner, 149 T.C. No. 7 (2017), the Tax Court held that payments made from
Continue Reading Tax Court Issues Opinion Striking Down Captive Insurance Arrangement
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
Recently, a Colorado business protested the IRS’ disallowance of their business expenses. The IRS alleges that the taxpayer was a Colorado medical marijuana dispensary to which Section 280E applies, as
Continue Reading Colorado District Court: IRS Enforcement of Section 280E Is Not A Criminal Investigation
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