News & Analysis as of

Tax Liability Appeals Internal Revenue Service

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

Foodman CPAs & Advisors

¿Puedes Apelar Al IRS?

Los contribuyentes tienen derecho a apelar al IRS. Entender cómo apelar al IRS es fundamental y los contribuyentes deben considerar contratar representación para disminuir los riesgos de litigio. Sólo los abogados, contadores...more

Foodman CPAs & Advisors

Can You Appeal The IRS?

Taxpayers have the right to appeal the IRS. Understanding how to appeal the IRS is critical and Taxpayers ought to consider retaining representation in order to diminish the risks of litigation. Only attorneys, certified...more

Cozen O'Connor

Notice of Appeal - A quarterly newsletter reviewing Third Circuit opinions impacting white collar defense lawyers - March 2024

Cozen O'Connor on

Defendant and his co-conspirators firebombed an informant’s house and killed several individuals. Six weeks into their trial on related charges, the Government disclosed that one of the defense attorneys previously worked as...more

Freeman Law

The IRS Appeals Office

Freeman Law on

The IRS Independent Office of Appeals (“IRS Appeals”) was established to provide an “independent” IRS function that is separate and independent from the IRS’s compliance functions that maintain responsibility for collecting...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

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

Jones Day on

A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Jones Day

Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference

Jones Day on

In this installment of Jones Day's continuing series of videos focusing on tax disputes, partner and tax litigator Chuck Hodges explains the Appeals Judicial Approach and Culture ("AJAC") Project's rules and procedures and...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

McDermott Will & Emery

Seventh Circuit Upholds Lien Notice despite Incorrect Name

McDermott Will & Emery on

When you do not pay your taxes, the Internal Revenue Service (IRS) has the power to file a “lien” on your property under Internal Revenue Code section 6321. The lien attaches “upon all property and rights to property, whether...more

Jones Day

Jones Day Presents: Strategies for Dealing with the IRS: Alternative Dispute Resolution

Jones Day on

This video is the third in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage three - the IRS post-appeal mediation process, in which the taxpayer and appeals...more

Carlton Fields

Cost-Sharing Regulations Revived By Ninth Circuit

Carlton Fields on

The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations. The decision, issued on July 24, revives certain regulatory...more

Burr & Forman

South Carolina Tax Litigation Update: First Quarter 2018

Burr & Forman on

There were several notable state tax opinions issued by the South Carolina Administrative Law Court, Court of Appeals, and Supreme Court in the 1st quarter of 2018. A number of tax cases are also pending before the Court of...more

Burr & Forman

IRS Appeals Announces a Return to In-Person Settlement Cases

Burr & Forman on

The IRS and taxpayers often disagree in tax audits and other tax-related matters. The IRS Office of Appeals was established as a separate and independent office within the IRS, whose mission is to resolve these tax disputes,...more

Burr & Forman

The End of an Era: IRS Ends In-Person Settlement Conferences

Burr & Forman on

Taxpayers often have disputes with the IRS, whether through an income tax audit or as a result of actions by IRS officials to collect federal taxes. To resolve these disputes administratively within the IRS, the IRS many...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Balch & Bingham LLP

Healthcare.gov: No 2015 Employer Subsidy Notices

Balch & Bingham LLP on

On September 18, 2015, the Centers for Medicare and Medicaid Services (CMS) published a set of “Frequently Asked Questions Regarding the Federally-Facilitated Marketplace’s (FFM) 2016 Employer Notice Program.”...more

18 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide