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Internal Revenue Service Penalties Tax Liability

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.  
Allen Barron, Inc.

The Risk of California FTB Audits is Increasing

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Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...more

Freeman Law

Tax Cout in Brief | Christiansen v. Commissioner

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The Tax Court in Brief - Freeman Law’s “The Tax Court in Brief” covers substantive Tax Court opinion, providing a brief of its decisions in clear, concise prose....more

Frost Brown Todd

Substantiating the Right to Claim QSBS Tax Benefits | Part 1

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Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more

Vedder Price

IRS Extends Transitional Relief for Digital Asset Broker Reporting and Backup Withholding

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On June 12, 2025, the Internal Revenue Service (IRS) released Notice 2025-33 which extends for an additional calendar year the transitional relief initially provided in Notice 2024-56 to brokers required to report digital...more

Allen Barron, Inc.

You Need an Experienced Tax Attorney when Tax Issues Strike

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Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more

Bricker Graydon LLP

Don’t Forget About the IRS When Correcting Delinquent Plan Contributions

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Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more

Hone Maxwell

When is a U.S. International Tax Attorney Needed?

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Individuals and businesses are frequently navigating transactions that span multiple countries. These transactions are often complex, as they navigate multiple jurisdictions’ unique — and often complicated — taxation systems....more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 4

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As discussed in Part 2, there are many ways social media creators earn income. Social media income, like all income, needs to be reported on federal tax returns....more

Allen Barron, Inc.

Why You Need a Lawyer for an IRS Audit

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Why do you need a lawyer for an IRS audit? Have you received an IRS audit notification (IRS form letter 2205-A, 2205-B, or 566)? What do you need to know?...more

Freeman Law

Posts, Profits, & Penalties | Tax Law & Social Media | Part 3

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The IRS Has Eyes - Having any presence on social media—even sans influencer following or income—can and may be used against you by the IRS. Have you ever Googled yourself? You will likely be shocked at how much...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Being aggressive on your mistakes could be a bad idea

Many moons ago, I got a call from a bank with a problem. For two decades—yes, twenty years—they had failed to include bonuses as part of plan compensation. The kicker? They were supposed to. This wasn’t a gray area; the plan...more

Eversheds Sutherland (US) LLP

House tax bill proposes major changes to the Employee Retention Tax Credit (ERTC)

On May 12, 2025, the Republicans on the House Committee on Ways and Means introduced a broad tax reform bill that includes sweeping changes to the Employee Retention Tax Credit (ERTC), also commonly known as the ERC. Chief...more

Farella Braun + Martel LLP

Insider Transaction Traps for the Unwary

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today I'm joined by David Sacarelos, a principal at Baker Tilly. We do a deep dive into the penalties under the Internal Revenue Code sections...more

Jaburg Wilk

Extensions, Amendments and Scams – Three Things to Keep Your Eye on During Tax Season

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As the April 15, 2025 deadline approaches, it’s essential to be prepared for filing your federal tax return. Whether you’re ready to submit your return or need more time, understanding the available options will help ensure a...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

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For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...more

Cadwalader, Wickersham & Taft LLP

Comments Would Limit Circular 230 Proposed Regulations

On December 26, 2024, the IRS published proposed regulations on Circular 230, which governs the conduct of practitioners who practice before the IRS. The New York State Bar Association Tax Section (NYSBA) has submitted...more

Husch Blackwell LLP

Impending IRS Workforce Cuts Mean Taxpayers Should Act Now to Resolve IRS Issues

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The New York Times reported on March 4, 2025, that the Trump administration is aiming to cut half of the Internal Revenue Service’s workforce by the end of the year. The cuts are reportedly across all divisions of the IRS,...more

Proskauer - Tax Talks

Final Regulations Issued for Certain Partnership Related Party Basis Adjustment Transactions

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On January 10, 2025, the Treasury Department and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “regulations”) classifying certain partnership related party basis adjustment transactions and...more

Fleurinord Law PLLC

Real Housewives Star Peter Thomas’ Payroll Tax Evasion Case: What Every Small Business Owner Must Know

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From Reality TV to Real-Life Tax Fraud: Peter Thomas’ $2.5 Million Scandal - Peter Thomas, best known for his appearances on The Real Housewives of Atlanta, was sentenced on December 19, 2024, to 18 months in federal prison...more

Allen Barron, Inc.

The Taxpayer Bill of Rights - 10 Essential Rights for U.S. Taxpayers

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Are you aware of the Taxpayer Bill of Rights?  We are reminded, especially during tax season, that taxpayers have 10 essential rights when dealing with the Internal Revenue Service. The IRS expects its employees to understand...more

Latham & Watkins LLP

Treasury Finalizes Controversial Regulations on IRS Penalty Oversight, but Debate Continues

Latham & Watkins LLP on

Section 6751(b), designed to ensure supervisory oversight amid rising penalty assertions in settlement negotiations, has been contentious due its ambiguity, and the final regulations may not resolve the debate....more

Bass, Berry & Sims PLC

2025 Changes to ACA Employer Information Reporting Obligations and the Employer Shared Responsibility Penalties

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In December 2024, Congress and President Biden passed two laws—the Paperwork Burden Reduction Act (PBRA) and the Employer Reporting Improvement Act (ERIA)—that made important changes to employers’ responsibilities regarding...more

Ropes & Gray LLP

IRS Issues Final Regulations Requiring Disclosure of Certain “Basis Shifting” Transactions Involving Partnership Distributions and...

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The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) published final regulations on January 14, 2025 (the “Regulations”) requiring taxpayers and their material advisors to disclose...more

Freeman Law

National Taxpayer Advocate’s Annual Report Highlights Issues Plaguing the IRS

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In her annual report to Congress for 2024, National Taxpayer Advocate (“NTA”) Erin M. Collins identified the processing of Employee Retention Credits (“ERCs”), the administration of civil penalties, and changes to the...more

Kilpatrick

Approaching Deadline: Reporting for ISO Exercises and ESPP Stock Transfers Due Beginning January 31, 2025

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This alert is a reminder of the approaching deadlines for certain year-end reporting requirements applicable to corporations that issue stock to employees (including former employees) upon the exercise of certain stock...more

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