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Internal Revenue Service Tax Liability Underpayment

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.  
Vinson & Elkins LLP

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

Vinson & Elkins LLP on

Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more

Freeman Law

Tax Court in Brief | Mulu v. Comm'r | Accuracy-Related Penalty and No Reasonable-Cause Excuse

Freeman Law on

Summary: In this non-precedential opinion (see section 7463(b)), the Tax Court addresses whether or not to uphold an accuracy-related penalty assessed to taxpayer, Ashenafi Getachew Mulu (Mulu). Mulu hired David...more

Freeman Law

Accuracy-Related Penalties: The Burdens of Proof and Production

Freeman Law on

Accuracy-related penalties under section 6662 are among the most common penalties in the Tax Code.  As a result, they are often at issue in tax litigation against the IRS.  That raises the question: What are the burdens of...more

Oberheiden P.C.

Eleven of the IRS's Enforcement Priorities During the 2021 Tax Season

Oberheiden P.C. on

It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more

Freeman Law

The Tax Court in Brief

Freeman Law on

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

Foodman CPAs & Advisors

IRS can Prove that a Taxpayer Under-Reported Income

There are Taxpayers that understate income, overstate expenses and present fraudulent claims on their tax returns for credits and deductions.  These Taxpayers run the risk of being identified by the IRS and having IRS...more

McDermott Will & Schulte

Weekly IRS Roundup February 25 – March 1, 2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more

Foodman CPAs & Advisors

IRS Accuracy Related Penalties is the number one most litigated tax issue

The National Taxpayer Advocate 2017 Report to Congress states that the Accuracy-Related Penalty under Internal Revenue Code Section 6662 remains the number one most litigated tax issue and has been over the last four years. ...more

Foodman CPAs & Advisors

Understanding how IRS identifies and selects Individual Tax Returns for Automated Underreporter Review

Foodman CPAs & Advisors on

The IRS Automated Underreporter Matching Process matches Tax Returns against Information Returns. IRS states that there were approximately 150 million individual tax returns filed in 2017 and about 25 million of them (17%)...more

Foodman CPAs & Advisors

IRS and Accuracy

According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more

Cooley LLP

Blog: Changes to Handling of Underpayment of Taxes by VC Funds, and to the Concept of the “Tax Matters Partner”

Cooley LLP on

Certain important changes took effect on January 1, 2018 regarding underpayment of taxes by partnerships as well as the handling of tax inquiries including audits. The biggest change is that the IRS can now come to collect...more

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