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IRS Further Combats Basket Contract Transactions with Proposed Regs

The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them...more

Tax Court Decision on Family Business Affecting Income Tax, Estate Tax

In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the court refers to by its...more

Travel Alert: How IRS Debt Can Affect Your Passport

By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS will send a Notice called a...more

ERC Claims on Hold While IRS Figures Out What it Thinks is Real

The IRS recently issued a press release regarding its “continuous efforts to combat dubious Employee Retention Credit (ERC) claims” to announce an initial round of over 20,000 notification letters of disallowed ERC claims....more

It’s So Hard to Say Goodbye to USA: Expatriation and the IRS

Ever thought about packing it all up and starting that romantic, expatriate life abroad? Ever felt like these parts were just so wild, it was time to find yourself a new passport? Expatriation, where a US citizen renounces...more

When Taxpayer and IRS Can’t Agree, the Tax Court Must Intervene

On remand for re-calculation of 4 errors in deficiency amounts, concerning years 2003, 2004, 2005, and 2006, the Tax Court entered final revised decisions based on the Commissioner’s twice-revised Rule 155 computations....more

Tax Court Confirms Taxpayer’s Right to Dismiss Their Own Lawsuit

An interesting recent Tax Court decision seems to indicate that taxpayers have clear autonomy with regards to judicial review as well as retracting judicial review of “seriously delinquent tax debt.” ...more

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