For 34 years, the Annual Tax Controversy Institute has been among the preeminent tax conferences in the United States exclusively dedicated to tax controversy and tax litigation! This year, I was honored and privileged to serve as Chair of The Annual Tax Controversy Institute.  Read More

The explosion of virtual currency has created challenging tax reporting issues for taxpayers and tax professionals alike. But does this uncertainty mean the federal government will shy away from prosecuting criminal tax cases involving the failure to report virtual currency? The odds-on favorite answer is simply: no. Sandra R. Brown examines virtual currency and the […] Read More…

The Internal Revenue Service has broad authority to examine books and records and interview witnesses for the purposes of determining the liability of any person for taxes, penalties or interest and collecting any liability.  This authority includes the power to issue summonses, including to third-parties.  Under Powell v United States, 379 U.S. 48 (1964), the […] Read More…