Published Articles

Tax audits down overall; wealthier taxpayers face highest risk

Appeals Judicial Approach and Culture (AJAC) Project Update: IRS Appeals as the Impartial Evaluator, July 18, 2013

Coming to America - Bar Bulletin for the MD State Bar Association, January 15, 2013

IRS weighs in on bitcoin taxation

IRS Relaxes Rules for Streamlined Installment Agreements - July 12, 2012

How NRIs' India mutual funds are taxed in US - April 27, 2012

Ex-Pat Act to Close the Door - May 29, 2012

IRS reopens Offshore Voluntary Disclosure Program - IR-2012-5, Jan. 9, 2012

Refund of Offshore Penalty for Foreign-Resident Taxpayers - December 9, 2011

Is the New IRS Voluntary Classification Settlement Program For You? - November 30, 2011

The IRS Softens Its Requirements for In-Business Offers in Compromise (OIC) - November 7, 2011

Hurricane Prompts IRS to Extend Due Date for Offshore Voluntary Disclosure Initiative Requests - August 26, 2011

Offshore Voluntary Disclosure Deadline is Quickly Approaching - August 9. 2011

Maryland is Hitting the Brakes on Delinquent Taxpayers - July 2011

Tax Law Updates - May, 2011

IRS FAQ - May 6, 2009

Journal of Tax Practice and Procedure - June, 2010

Tax Focus 2010: Are You Ready? - April 2010

Who's Next in Line for and IRS Audit

Reporting Requirements for FBAR: Generally and Under the IRS' Amnesty Program

Bankruptcy Filing and Federal Employment Taxes - May 8, 2009

Maryland Tax Amnesty Proposal

IRS Fails to Nab Payroll Cheats - FinancialWeek.com - August 25, 2008

Reprinted with permission from FinancialWeek.com

Life Cycle of a Federal Tax Controversy - JOURNAL OF TAX PRACTICE & PROCEDURE - December 2006 - January 2007

Reprinted with the publishers permission from the JOURNAL OF TAX PRACTICE & PROCEDURE

Life Cycle of a Federal Tax Controversy - Maryland Bar Journal - November 2006

Reproduced with the permission of the Maryland Bar Journal

Recent Tax Initiatives

The updated estimate of the overall gross tax gap for Tax Year 2001 is now $290 billion. Over 80% is from underreported taxes. Since 2001, the IRS increased its enforcement revenues from $33.8 billion in 2001 to $47.3 billion in 2005. Further audits of taxpayers earning $100,000+ topped 221,000 in fiscal year 2005.

Making Your Tax Case Before IRS Appeals

There can be no doubt that the IRS is revitalizing its collection efforts. From our prior newsletter, the Robinette opinion was decided by the 8th Circuit only a few weeks ago. It touched on a theme becoming more prevalent among the tax community: making the administrative record while looking to the statute of limitations.

Section of Taxation

On Tuesday, February 28th, the 9th Circuit published its decision in Commissioner v. Ewing, 2006 WL 463788 (9th Cir.). Ewing deals with the denial of an innocent spouse claim where the couple was still married, and the wife believed the husband would be satisfying 'his share' of the self-assessed tax liability. The ruling identifies...