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Appeals Penalties Tax Court

Bilzin Sumberg

Playing Battleship with the IRS: Did They Sink Our Battleship?

Bilzin Sumberg on

In prior posts, I discussed the dangers of playingBattleship with the IRS and how taxpayers scored “a hit”.  Recently, taxpayers took another turn in the game and scored another hit with the District Court’s recently issued...more

Baker Botts L.L.P.

Taxpayer Assistance and Service Act – Tax Controversy Perspective

Baker Botts L.L.P. on

On January 30, 2025, a bipartisan group of US Senators released a discussion draft of the Taxpayer Assistance and Service Act (“TAS Act”), a legislative proposal that, if passed, could significantly alter tax controversy...more

Holland & Knight LLP

IRS Authority to Assess Certain Foreign Information Return Penalties Restored by D.C. Circuit

Holland & Knight LLP on

The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) on May 3, 2024, reversed the U.S. Tax Court (USTC) in Alon Farhy v. Commissioner, No. 23-1179 (D.C. Cir. May 3, 2024) by holding that...more

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