Our Blog

Journal of Accountancy – Enlist and Ally in TAS by CORY STIGILE

When the IRS’s processes are not working as they should, the Taxpayer Advocate Service (TAS) may be able to help. Sec. 7811 authorizes TAS to issue a taxpayer assistance order if the taxpayer is suffering, or about to suffer, a significant hardship as a result of the way the internal revenue laws are being administered. […] Read More…

Read More

FinCEN Giveth With One Hand, Taketh With the Other by Confirming Virtual Currency Isn’t Reportable on an FBAR Form but Proposing to Require Reporting in Future and More Reporting by Money Services Businesses By EVAN J. DAVIS

The intersection of virtual currency with Bank Secrecy Act (BSA) and tax laws frequently results in a square peg, round hole problem.  All too often, regulators try to solve the problem as would a toddler, by pounding as hard as possible to make the square peg fit in the round hole.  Witness the IRS treating […] Read More…

Read More

Time for Another IRS Reorganization by Steve Toscher and Robert S. Horwitz

Last week, the Commissioner issued the Taxpayer First Act (TFA) report to Congress. The report will establish the framework of the IRS for the next 20 year, with a goal of improved employee training, increased taxpayer accessibility and making the IRS a more technology-driven organization.  So what is the TFA and why is there a […] Read More…

Read More

IRS Issues Regulations on the Non-Deduction of Fines and Penalties Under the New More Complex Section 162(f) by Robert S. Horwitz

Occasionally I feel sorry for the attorneys in IRS National Office who have to write regulations for the tax laws enacted by Congress.  Gone are the days when Congress had members who could write simple, logical statutes, like the original sec. 162(f), enacted in 1969: No deduction shall be allowed under subsection (a) for any […] Read More…

Read More

A Return by Any Other Name by ROBERT S. HORWITZ

You’d think deciding whether something is a federal tax return would be easy: if it’s on a return form put out by the IRS, containing information sufficient to determine the taxpayer’s tax liability and signed under penalty of perjury by the taxpayer it’s a valid tax return.[1]  If only it were that simple.  Whether a […] Read More…

Read More

USC Gould School of Law 2021 Tax Institute – January 25-27, 2021

Just a quick reminder that there is still time to register for the USC Gould School of Law 2021 Virtual Tax Institute to be held Monday through Wednesday, January 25-27, 2021.  This year’s Institute has a stellar line up of tax superstars.  Learn the latest tax law developments for corporations, privately held businesses, individuals, partnerships […] Read More…

Read More

IRS Loses Another Non-Willful FBAR Case by ROBERT S. HORWITZ

In December I had an FBAR roundup, where I wrote about three recent FBAR cases, two willful cases the IRS won (the Fourth Circuit’s decision in US v. Horwitz and the district court’s decision on remand in Bedrosian v. US) and the IRS loss in a non-willful case (US v. Bittner).  This week a district […] Read More…

Read More

STEVEN TOSCHER, DENNIS PEREZ and MICHEL STEIN to Speak on Federal and California Tax Update for Individuals

We are proud to be working with Professor Annette Nellen and CalCPA and to be part of the Titans of Tax Tour 2021. Join Professor Nellen and her team of tax experts for the latest in the world of tax and join us for the cutting edge developments of Internal Revenue Service and California Franchise Tax Board Enforcement […] Read More…

Read More

CORY STIGILE to Speak on The IRS Collection Process: Initial Notice to Successful Settlement

We are pleased to announce that Cory Stigile, along with Larry Wolfe and Stan Green will be speaking at the upcoming AICPA webinar, “The IRS Collection Process: Initial Notice to Successful Settlement” on Monday, January 11, 2021, 10:00 a.m. – 11:45 a.m. (PST). Join this webcast to discover best practices for working with clients in […] Read More…

Read More

A Big Win for Taxpayers in a Non-Willful FBAR Penalty Case (but Two Losses in Willful FBAR Penalty Cases) by ROBERT S. HORWITZ

It has been a while since I blogged on FBAR cases, but three cases over the past few months deserve mention.  Two were willful cases where the courts held that the taxpayers were liable for the FBAR willful penalty: the Fourth Circuit’s affirmance of the district court’s grant of the Government’s summary judgement motion in […] Read More…

Read More

The Due Process Protections Act of 2020 – Judicial Oversight for Federal Prosecutors by SANDRA BROWN

The Due Process Protections Act (DPPA)[i], was signed into law and became effective October 21, 2020.  The DPPA effectively provides federal judges with greater supervisory authority over the federal government’s disclosure of exculpatory evidence in criminal prosecutions. A prosecutor’s obligation to disclose exculpatory evidence to the defense after charging a defendant with a federal crime […] Read More…

Read More

Save the Date – USC Gould School of Law 2021 Tax Institute – January 25-27, 2021

We hope you are all staying healthy and safe. It has been challenging year—but it looks as if we are starting to turn the corner. Please join us Monday through Wednesday, January 25-27, 2021 for the USC Gould School of Law 2021 Virtual Tax Institute. This year’s Institute has a stellar line up of tax […] Read More…

Read More

Important This site makes use of cookies which may contain tracking information about visitors. By continuing to browse this site you agree to our use of cookies.