Tax Penalty Relief – Reliance on Tax Advisor

The Internal Revenue Manual (IRM) contains a Penalty Handbook intended to serve as the foundation for addressing the administration of penalties by the IRS. It is the “one source of authority for the administration of penalties. . .”( Internal Revenue Manual (IRM)  (02-22-2008). Refer to IRM 9.1.3, Criminal Investigation – Criminal Statutory Provisions and Common […] Read More…

Read More

Current IRS Enforcement Priorities

Current IRS Enforcement Priorities. The international arena will continue to test the enforcement resources of the IRS for years to come. There will be ongoing, enhanced coordination with treaty partners and international organizations (six of nine LMSB Tier 1 issues involve international components and LMSB Counsel lawyers have been trained in the fundamentals of international […] Read More…

Read More

Introduction / Legal Disclaimer

Welcome to the Tax Litigation (Civil & Criminal) Report! This Report is intended solely for tax professionals to share and exchange general (non-client specific) thoughts and comments regarding recent developments, procedures, cases and authorities involving federal tax disputes and the representation of taxpayers before the Internal Revenue Service in examinations, tax collection matters, administrative Appeals, tax litigation, […] Read More…

Read More