Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose.
The Week of October 31 – November 6, 2020 -
Glade Creek Partners,...more
11/12/2020
/ Charitable Deductions ,
Clerical Errors ,
Conservation Easements ,
De Novo Standard of Review ,
Income Taxes ,
IRS ,
Joint and Several Liability ,
Joint Tax Returns ,
Jurisdiction ,
Material Misstatements ,
Scope of Review ,
Spouses ,
Tax Court ,
Tax Deductions ,
Tax Liability ,
Underpayment
Section 548 of the Bankruptcy Code provides a bankruptcy trustee (or the debtor-in-possession) the power to set aside or “avoid” certain transfers of the debtor’s assets out of the bankruptcy estate that may otherwise place...more
Jason B. Freeman and Matthew L. Roberts of Freeman Law, PLLC discuss the recent Second Circuit decision in Trump v. Vance. The case involves the ongoing battle between President Trump and the Manhattan District Attorney's...more
IRS debt can be a life-changing burden. But for some taxpayers, an offer in compromise may be an avenue to get rid of that tax debt and to receive a fresh start. When a taxpayer qualifies for an offer in compromise, the IRS...more
What is the Report of Foreign Bank and Financial Accounts (FBAR)?
Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more
10/21/2020
/ Bank Secrecy Act ,
Civil Monetary Penalty ,
Criminal Investigations ,
Criminal Penalties ,
FBAR ,
Filing Requirements ,
FinCEN ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Government Investigations ,
IRS ,
Recordkeeping Requirements ,
Regulatory Authority ,
Statutory Authority ,
Tax Penalties
The IRS has been focused on enforcement efforts targeting conservation easement transactions. And IRS data indicates that more enforcement efforts lie ahead. The Senate Finance Committee, which has been engaged in a...more
In this episode of The Freeman Law Project podcast, Jason B. Freeman discusses cryptocurrency and blockchain legal issues, including regulation and taxation. This primer episode provides an introduction into the technology...more
In the latest podcast episode, Jason B. Freeman of Freeman Law, PLLC and Eric Green of Tax Rep Network cover the recent New York Times article regarding President Trump's past taxes. The NYT coverage includes allegations that...more
As tax time approaches for many, taxpayers and tax professionals alike are engaging in the annual ritual of gathering their cryptocurrency transactions and seeking out the latest and greatest guidance from the IRS on the...more
International information return penalties are civil penalties assessed by the IRS against a United States person for failing to timely file complete and accurate international information returns required by specific...more
10/8/2020
/ FBAR ,
Filing Requirements ,
Foreign Corporations ,
Foreign Tax Credits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
IRS ,
Reporting Requirements ,
Statute of Limitations ,
Tax Returns
Along with tax penalties and tax lien filings, the IRS’s ability to seize a taxpayer’s property is one of its most potent weapons to encourage tax compliance. That is, in part, what makes a recent report from the Treasury...more
Sensitive audits present the tax practitioner with unique challenges. They require the exercise of judgment and discretion, as well as an understanding of administrative procedure and even a command of constitutional and...more
10/1/2020
/ Accountants ,
Civil Liability ,
Criminal Investigations ,
Evidence Suppression ,
Fifth Amendment ,
Fourth Amendment ,
Internal Revenue Code (IRC) ,
IRS ,
Parallel Proceedings ,
Privileged Communication ,
Risk Mitigation ,
Tax Audits ,
Tax Fraud ,
Tax Penalties ,
Tax Returns