Appeals Judicial Approach and Culture (AJAC) Project Update: IRS Appeals as the Impartial Evaluator, July 18, 2014
Coming to America - Bar Bulletin for the MD State Bar Association, January 15, 2013
IRS Relaxes Rules for Streamlined Installment Agreements - July 12, 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
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
Bankruptcy Filing and Federal Employment Taxes - May 8, 2009
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
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.
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.
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...