News & Analysis as of

Tax Liability Appeals Deficiency Notices

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

An Update on Section 6751 Penalties

McDermott Will & Emery on

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

McDermott Will & Emery

A Notice of Deficiency Is Not Set in Stone

McDermott Will & Emery on

A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the...more

McDermott Will & Emery

Sacked in Tax Court! Procedural Missteps by the IRS Leave the Government’s Blindside Exposed

McDermott Will & Emery on

In Kearse v. Commissioner, T.C. Memo 2019-53, the Tax Court held the Internal Revenue Service (IRS) abused its discretion as part of the taxpayer’s Collection Due Process hearing (CDP hearing) because the Appeals officer...more

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