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Internal Revenue Service Business Taxes Appeals

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Snell & Wilmer

IRS Issues Interim Guidance Eliminating the Acknowledgement of Facts and Expanding Access To Dispute Resolution Programs

Snell & Wilmer on

The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. Specifically, the IGM (1) removes the...more

Allen Barron, Inc.

What to do if You Receive an IRS Audit Notification Letter 0724

Allen Barron, Inc. on

What should you do if you receive an IRS audit notification letter? Why should you consider engaging an experienced IRS audit and tax attorney who represents U.S. taxpayers facing an IRS audit or any other federal or state...more

Freeman Law

Court Strikes Down Largest Non-Willful FBAR Penalty Ever

Freeman Law on

I have previously written on the Bittner (E.D. Tex.) case in a prior Insight.  Briefly summarized, the taxpayer, Mr. Bittner, was a dual citizen of both Romania and the United States.  However, in 1990, he moved back to...more

Bradley Arant Boult Cummings LLP

Recent Rulings on “Family Limited Liability Entity” Election Create Traps for the Unwary

Although every LLC, limited partnership or other pass-through entity doing business in Alabama, and even those simply organized under Alabama law, are subject to an annual business privilege tax (BPT), certain entities can...more

Lowndes

Should You Abandon An Underperforming Partnership?

Lowndes on

Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more

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