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 DeloreanCivil Tax Penalties
Horse Breeding and Training Expense Deductions? Tax Court Says Neigh
By Adam Young on
In a June 9 opinion, the Tax Court held that a married couple were not engaged in horse breeding and training activities for profit and sustained the IRS’s disallowance…
Continue Reading Horse Breeding and Training Expense Deductions? Tax Court Says NeighTaxpayer Assistance and Service Act Title V: Tax Return Preparers
This article is the fifth in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…
Continue Reading Taxpayer Assistance and Service Act Title V: Tax Return PreparersThe Taxpayer Assistance and Service Act: Title III: Judicial Review
This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service…
Continue Reading The Taxpayer Assistance and Service Act: Title III: Judicial ReviewTax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
By Fox Rothschild LLP on
In Graev III, issued late last year, the Tax Court held that the Commissioner must comply with section 6751(b)(1) as part of his burden of production for tax penalties. …
Continue Reading Tax Court Holds Commissioner Failed to Comply with Supervisor Approval Requirement for Fraud Penalty
Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding
By Fox Rothschild LLP on
Recently, the written supervisory approval requirement of Section 6751(b) has been one of the primary issues in Tax Court litigation concerning penalties that the IRS has asserted against taxpayers. The…
Continue Reading Tax Court Addresses Supervisor Approval Requirement in Partnership-Level Proceeding