In a recent case of first impression, the U.S. Tax Court has held that it does not have to rely solely upon the administrative record in determining whether the IRS erroneously certified a taxpayer as having a seriously...more
The Internal Revenue Service (“IRS”) faces many challenges when attempting to collect unpaid taxes from taxpayers with foreign assets who reside abroad (“international delinquent taxpayer” or “IDT”). Common obstacles include...more
Last week, the Internal Revenue Service (“IRS”) published another friendly reminder that it was recently vested with the authority to revoke passports and deny passport applications for those with “seriously delinquent tax...more