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Fourth Amendment Internal Revenue Service Tax Returns

The Fourth Amendment to the United States Constitution protects citizens from unreasonable searches and seizures and provides that warrants may only be granted upon findings of probable cause. The Fourth... more +
The Fourth Amendment to the United States Constitution protects citizens from unreasonable searches and seizures and provides that warrants may only be granted upon findings of probable cause. The Fourth Amendment applies to the States via the Due Process Clause of the Fourteenth Amendment.  Important areas of Fourth Amendment jurisprudence flow from questions surrounding the definitions of "search" and "seizure," the applicability of the Amendment to so-called "stop and frisk" situations, the level of control that must be exerted by law enforcement before an individual is deemed "seized," and the "exclusionary rule," just to name a few.    less -
Gray Reed

Balancing Privacy and Tax Enforcement in the Digital Age

Gray Reed on

The Internal Revenue Service was aware of significant underreporting of cryptocurrency on tax returns and used one of its investigative tools (i.e., a John Doe summons) in 2016 to seek financial information on thousands of...more

Freeman Law

Representing Taxpayers in Sensitive Audits: A Look at the Fundamental Challenges of an Eggshell Audit

Freeman Law on

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

Dorsey & Whitney LLP

The Supreme Court - February 25, 2020

Dorsey & Whitney LLP on

Today, the Supreme Court of the United States issued the following four opinions: Rodriguez v. FDIC, No. 18-1269: The Internal Revenue Service (“IRS”), under its statutes and regulations, allows an affiliated group of...more

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