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
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IRS Audits of Cannabis Companies and the Importance of Substantiation
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
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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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Trends in IRS Compliance Activities Through Fiscal Year 2016
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
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Tax Court Issues Opinion Striking Down Captive Insurance Arrangement
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
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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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Colorado District Court: IRS Enforcement of Section 280E Is Not A Criminal Investigation
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
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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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IRS Unveils Fast Track Mediation Collection Program, Offering Expedited Resolution for Certain Collection Cases
Effective November 18, 2016, Revenue Procedure 2016-57 established the Small Business/Self-Employed (“SB/SE”) Fast Track Mediation Collection (“FTMC”) program to allow taxpayers and the IRS to resolve disputes quickly with an
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