News & Analysis as of

Internal Revenue Service Audits Appeals

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

Allen Barron, Inc. on

What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Allen Barron, Inc.

The Step Doctrine and How it Applies to IRS, State, and California Tax

Allen Barron, Inc. on

It is important to understand the step doctrine and how it applies to IRS audits and state tax investigations, including California tax audits. The "step doctrine" is a concept not directly found in federal or California...more

Rivkin Radler LLP

Collecting an Individual’s Unpaid Taxes from Their Controlled Entities

Rivkin Radler LLP on

An anonymous thinker, lost to history, is credited with having said that the unofficial motto of the IRS is, “We have what it takes to take what you have.” In some instances, the truth of the above statement is manifested in...more

McDermott Will & Emery

Extending the Statute of Limitations for Assessing Federal Tax

McDermott Will & Emery on

We previously provided an overview of the time limits imposed on the Internal Revenue Service (IRS) for assessing federal tax. The general rule is that the IRS must assess tax within three years from the later of the due date...more

McDermott Will & Emery

Weekly IRS Roundup November 29 – December 3, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 29, 2021 – December 3, 2021... November 29, 2021: The IRS published a news release...more

McDermott Will & Emery

Tax Court Holds That Form 870-AD Is Not a Binding Settlement Agreement

McDermott Will & Emery on

A recent US Tax Court Memorandum Opinion held that a settlement agreement embodied in Internal Revenue Service (IRS) Form 870-AD does not preclude the IRS from reopening an audit and issuing a notice of deficiency. In Howe...more

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