On November 10, 2022, US President Joe Biden announced his intent to nominate Danny Werfel to serve as Commissioner of the Internal Revenue Service. US Secretary of the Treasury Janet Yellen has expressed her support for...more
The recent Zhang v. United States case, Docket No. 21-17093 (9th Cir. Oct. 18, 2022), serves as a reminder that the Internal Revenue Service (IRS) can force you to disclose and share your tax information with foreign...more
On October 18, 2022, the Internal Revenue Service (IRS) announced the annual inflation adjustments for 2023 related to more than 60 tax provisions, with some increasing, some maintaining and some new additions to the list...more
US Congress will be giving the Internal Revenue Service (IRS) $79.6 billion over the next 10 years in an effort to put the agency back on the path to effective and efficient tax administration. The money will find lots of...more
On October 11, 2022, the Internal Revenue Service (IRS) announced draft changes to Schedule UTP, Uncertain Tax Position Return Statement, and Form 1120, Instructions for Schedule UTP, for the 2022 tax year (processing year...more
The Internal Revenue Service Independent Office of Appeals (IRS Appeals) is the administrative forum for taxpayers to attempt to resolve tax disputes prior to litigation. Subject to certain exceptions, taxpayers can file a...more
Since Chai v. Commissioner, an opinion by the US Court of Appeals for the Second Circuit subsequently followed by the US Tax Court in several opinions, there has been a substantial number of cases litigating issues involving...more
At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson stated that guidance and a new final form will be issued when the IRS and the US Department of the Treasury replace...more
Almost 11 months ago, the Internal Revenue Service (IRS) released a memorandum regarding the implementation of the Large Partnership Compliance (LPC) Pilot Program, including the identification, selecting and delivery of...more
In Mayo Found. for Med. Educ. & Rsch. v. United States, 131 S.Ct. 704 (2011), the Supreme Court of the United States made clear that administrative law rules apply to tax guidance like they do to other federal agency...more
Earlier this year, the Internal Revenue Service (IRS) announced the creation of a new Joint Strategic Emerging Issues Team (JSEIT). The new initiative, announced at the New York University School of Professional Studies Tax...more
9/8/2022
/ Criminal Investigations ,
Government Entities ,
Internal Revenue Code (IRC) ,
IRS ,
Large Business & International Division (LB&I) ,
Self Employed ,
Small Business ,
Tax Audits ,
Tax Exempt Entities ,
Tax Reform ,
Tax Returns
The phrase “it’s in the mail” is sometimes an excuse for one’s delinquency in filing tax returns. However, that is not necessarily the case for taxpayers who have submitted their individual tax returns during the COVID-19...more
In Notice 2022-36, the Internal Revenue Service (IRS) announced relief for taxpayers who failed to file certain tax and information returns with respect to tax years 2019 and 2020. The relief, which will be automatic, is...more
Since the Supreme Court of the United States’ decision in CIC Servs., LLC v. IRS was issued in May 2021, courts have grappled with how to apply the Anti-Injunction Act (AIA) in other contexts. The US Court of Appeals for the...more
On August 16, 2022, US President Joe Biden signed into law the Inflation Reduction Act of 2022 (Act). A press release from the White House touts the Act as one that will “lower the costs for families, combat the climate...more
On August 5, 2022, the US Court of Appeals for the District of Columbia Circuit upheld the US Tax Court’s bench opinion in favor of partners and investors in a refined coal business. The Internal Revenue Service (IRS) has...more
After months of back and forth, it appears that additional funding is on its way to the Internal Revenue Service (IRS). Senate Majority Leader Chuck Schumer (D-NY) released a statement yesterday on his agreement with Senator...more
The Internal Revenue Service (IRS) recently announced that it will hire 470 new revenue agents into the Small Business Self Employed (SB/SE) division. This effort is part of a larger IRS staffing initiative, following a...more
A war is currently waging in the tax world over when courts should give deference to the US Department of the Treasury’s regulations. (We have written extensively on this subject...) However, another potential war looms: Can...more
Debates have raged in recent years over the future of Chevron deference, particularly given the change in the makeup and views of the Supreme Court of the United States. We have written extensively on Chevron deference in the...more
On June 1, 2022, Judge Kathleen Kerrigan began her two-year term as Chief Judge of the US Tax Court. Her election as Chief Judge was announced earlier this year...more
In a memorandum dated April 19, 2022, the Internal Revenue Service’s (IRS) Independent Office of Appeals (IRS Appeals) acknowledged that it has a large backlog of cases that is slowing down the process of resolving cases with...more
We frequently write about developments at the US Tax Court, including noteworthy cases, administrative matters, and the status of presidentially appointed Judges and court-appointed Special Trial Judges...more
On March 23, 2022, the US Tax Court announced new proposed rules for practicing before it. The Court proposed three new rules, amendments to existing rules and changes to conform the existing rules to various forms. The...more
Tax penalties are always a hot topic here. The Internal Revenue Service (IRS) has a large arsenal when it comes to grounds for asserting penalties on income tax deficiencies, ranging from the common 20% penalty under Internal...more