IRS Commissioner Charles Rettig’s commitment to fighting tax fraud seems to have manifesteditself in at least one of his recent personnel moves. Starting September 1, the deputy chief of the Criminal Investigation division, Eric Hylton, will take over as commissioner of the Small Business/Self-Employed Division, and a couple days later, Darren Guillot will move from director of […] Read More…

Practitioners are disturbed by a possible legal stance of the Justice Department in the latest dust-up over foreign bank account reporting, which would negate reliance on a professional as a defense to willful penalties. Tax Notes talked with two practitioners following filings of a joint pretrial statement and proposed jury instructions in Dadurian that seemingly […] Read More…

The IRS has recently provided interim guidance to clarify actions IRS Examiners musttake to analyze and document Currency Transaction Report (CTR) data during an audit.  The Guidance, which is effective immediately, will be incorporated into IRM 4.10.4, Examination of Returns, Examinations of Income. Prior to incorporation, IRM 4.10.4 provided very little guidance on when and how to […] Read More…