In Big Apple Tompkins Realty LLC v. Commissioner, the Tax Court addressed a question of first impression: whether I.R.C. § 6234(a)’s 90-day petition filing deadline for partnerships subject to
Continue Reading Tax Court Holds BBA Partnership Petition Filing Deadline Is Not JurisdictionalIRS Large Business and International (LB&I) Division
The Growing Business of Sports: A Tax Playbook Review
Get your popcorn ready because there is nothing more exciting than the intersection of sports and tax! As a former Division II athlete, the current state of college sports and…
Continue Reading The Growing Business of Sports: A Tax Playbook ReviewBack to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the Delorean
Every January, businesses race to issue Forms W-2, 1099, and 1099-NEC, but a small typo in a Social Security Number (SSN) or Taxpayer Identification Number (TIN) can turn into a…
Continue Reading Back to the Future: Tax Edition — Correcting SSN/TIN Issues Before the IRS Repossesses the DeloreanNo Points for Participation: Passive Activity Rules and Loss Limitations
Classroom participation points may boost a child’s grade in history class, but merely raising your hand won’t get you far with the IRS. The passive activity loss rules under I.R.C.
Continue Reading No Points for Participation: Passive Activity Rules and Loss LimitationsIRS Makes Top Leadership Moves While Federal Government Remains Shuttered
As the federal government shutdown passes the two-week mark, and as thousands of Internal Revenue Service employees face furloughs and/or firings, the tax agency has announced a series of significant…
Continue Reading IRS Makes Top Leadership Moves While Federal Government Remains ShutteredIRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful
A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with…
Continue Reading IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is DoubtfulTaxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS Commissioner
The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for…
Continue Reading Taxpayer Advocate Offers Candid Assessment of State of IRS Workforce and Other Challenges Facing the New IRS CommissionerAuditor Releases “Snapshot” of IRS Workforce Revealing Devastating Extent of Initial Job Cuts
The Treasury Department’s Inspector General for Tax Administration (TIGTA) has released a report showing how the Internal Revenue Service has been dramatically impacted by government-wide efforts to reduce the size…
Continue Reading Auditor Releases “Snapshot” of IRS Workforce Revealing Devastating Extent of Initial Job CutsIRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
IRS Notice 2024-72, provides relief for individuals and businesses affected by terrorism in Israel.
Continue Reading IRS Provides Additional Extensions for Taxpayers Affected by Terrorist Attacks in Israel
IRS Going All in on Use of ArtificiaI Intelligence
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