Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law
Videocast: SALT Scoreboard – 2019 year in review
Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Effective Strategies for Elevating Issues
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Overview of IRS Appeals Judicial Approach & Culture Project (AJAC)
Jones Day Presents: Strategies for Dealing with the IRS: Alternative Dispute Resolution
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
Videocast: Sutherland SALT Scoreboard – 2nd Quarter Highlights
El 6/20/24, el IRS emitió el Consejo Fiscal 2024-59 para alertar a los contribuyentes que la mediación con el IRS puede ayudarlos a resolver sus problemas tributarios de manera temprana y efectiva. El IRS afirma que la...more
On 6/20/24, the IRS issued Tax Tip 2024-59 to alert taxpayers that mediation with the IRS can assist taxpayers to solve their tax issues early and effectively. IRS states that mediation with the IRS can be a more...more
Discover the latest global developments and planning opportunities to stay ahead of the curve at McDermott’s Tax Symposium 2024. Join us in Chicago for a full day of programming designed to equip corporate tax leaders with...more
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
I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more
Tax Litigation: The Week of October 10th, 2022, through October 14th, 2022 Cochran v. Comm’r, 159 T.C. No. 4 | October 12, 2022 | Greaves, J. | Dkt. No. 21002-16 Clark Raymond & Company, PLLC v. Comm’r, T.C. Memo. 2022-105 |...more
The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more
Two things are virtually certain in life: death and taxes. But, one more should be added to the list where the two converge—an IRS audit. Indeed, this scenario played out all too well for the “King of Pop,” Michael...more
Join us as we discuss important developments during these unique times, and bring you up to speed on current initiatives. Business are still facing unprecedented challenges, and we are here to provide insights. During...more
The 2020 year was . . . well, interesting. So, too, were the Tax Court decisions for the year. In this Insight, Freeman Law takes a closer look at the top 10 Tax Court cases of 2020. As a reminder, Freeman Law...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 16 – 20, 2019. September 16, 2019: The IRS issued a news release about time-limited...more
In the fourth installment of Jones Day’s series of video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains how the IRS’s new process...more
In the second installment of Jones Day’s video series on the IRS's Large Business & International Division ("LB&I") exam process, partner and tax litigator Chuck Hodges discusses changes in how the division issues Information...more
In 2016, the IRS's Large Business & International (LB&I) Division significantly altered its examination processes. In the first in a series of programs on LB&I strategies, Jones Day partner and tax litigator Chuck Hodges...more
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
A recent case decided by the US Tax Court reminds us that when you litigate a case in Tax Court, what happened during the Internal Revenue Service (IRS) examination and Appeals bears very little relevance (if any) once you...more
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
This video is the second in a four-part series on Jones Day's approach to dealing with the IRS. In it, partner Chuck Hodges discusses stage two – the IRS Office of Appeals. He describes the office as having one mission – to...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 18 – 22, 2019. February 19, 2019: The IRS issued a news release promoting online...more
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
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
In Albemarle Corp. v. United States, No. 2015-5015 (Fed. Cir. Aug. 13, 2015), the United States Court of Appeals for the Federal Circuit disallowed claims for refund related to foreign taxes paid by Albemarle Corporation...more